MACRA focuses on Value and Quality of Care
It is better to start ensuring your business processes support MIPS and APM requirements.
Under the direction of the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA), the Centers for Medicare & Medicaid Services (CMS) is charged with implementing a Quality Payment Program that pays healthcare providers for the quality of their work, not the quantity.
For starters, the federal agency is proposing to create two new payment systems:
- The Merit-based Incentive Payment System (MIPS) and
- Advanced Alternative Payment Models (APM).
CMS outlines four strategic goals:
- Design a patient-centered approach leading to better, smarter, and healthier care;
- Develop a program that is meaningful, understandable, and flexible for clinicians;
- Design incentives that drive delivery system reform principles and participation in APMs; and
- Ensure attention to excellence in implementation, effective communication, and operational feasibility.
CMS touts the MIPS program as a ?fresh start.? The program will retire the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (Value Modifier), and the Medicare Electronic Health Record (EHR) Incentive Program (or Meaningful Use), along with their individual financial penalties or rewards, in exchange for a positive, neutral, or negative payment adjustment.
Components of these programs are being carried forward into the MIPS program across four performance categories:
- Quality
- Resource use
- Clinical practice improvement activities (CPIA)
- Advancing care information (ACI)
For 2019, these performance categories will be weighted on a 0-100 scale (as shown in Figure A), and will contribute to a composite performance score. This score will be compared to a performance threshold that CMS will calculate based on available data from the 2017 reporting period. The scores from 2017 will determine payment adjustments in 2019.
The proposed rule changes the definition of an ?eligible professional? to include only physicians and traditional mid-level providers (physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists). There is flexibility in the legislation to expand and include other types of MIPS-eligible clinicians after the first two years of the program.
MIPS applies only to eligible clinicians, not to hospitals or other facility types. Also excluded are:
- Eligible clinicians in their first year of Medicare Part B participation
- Eligible clinicians defined as having a low volume threshold, which is proposed as Medicare annual billed charges of less than $10,000 and 100 Medicare patients or less
- Certain participants in advanced APMs
CMS expects the majority of eligible clinicians to participate in MIPS in the first year, with substantial growth of APMs in the future.
The 962-page proposed rule includes detailed information on :
- Scoring,
- Opportunities for additional support for small practices,
- Future inclusion of commercial payer and Medicaid APM models, etc.
The final rule will be published no later than Nov. 1, 2016, but it is better to start preparing than to wait.
Focus should be on reviewing quality metric reporting data, aligning the data to a quality initiative plan, and gaining a clear understanding of your patient population. It is good to review your business processes to ensure they support the MIPS/APM requirements.