While 2017 is considered a “transition year” for the Medicare Access and CHIP Reauthorization Act, better known as MACRA, it is certainly no time to coast. Over time, this physician-focused quality payment program will either reward, penalize or provide zero adjustment to a clinician’s reimbursement, depending on their performance.
While it may appear that the monetary impact of MACRA won’t be felt until the beginning of 2019, it is important to understand that this is not necessarily true. Those who are eligible in 2017 but choose not to submit data to MIPS or join an Advanced APM, will receive a maximum negative four percent adjustment penalty for nonparticipation. Understanding eligibility requirements and deciding your best option to participate in 2017 is critical to preventing the negative four percent penalty.
What Are the Goals of MACRA?
The strategic goals for MACRA are as follows:
- Improve outcomes and engagement through patient-centered MIPS and Advanced APM regulations
- Enhance clinician experience through easy-to-use tools
- Increase availability and adoption of robust Advanced APMs
- Promote program understanding and maximize participation
- Improve data and information sharing
- Ensure operational excellence in program implementation and ongoing development
The Centers for Medicare and Medicaid Services (CMS) estimates approximately 500,000 clinicians will be eligible to participate in MIPS in the first year of the program. For these participants, performance metrics will be submitted in March of 2018, with CMS feedback provided through the duration of the year. Payment adjustments – positive or negative – will be made on January 1, 2019.
What Are the MACRA Pathways?
In simple terms, this Quality Payment Program is designed to reward the delivery of high-quality patient care through one of two pathways: 1) the Merit-based Incentive Payment System (MIPS) or 2) Advanced Alternative Payment Models (Advanced APMs).
The Merit-based Incentive Payment System, called MIPS, streamlines three previous pay-for-performance programs and also adds a fourth component to promote the ongoing improvement and innovation to clinical activities. The four categories are as follows:
- Resource Use
- Clinical Practice Improvement Activities
- Advancing Care Information
Unlike the former one-size-fits-all payment programs, MIPS gives clinicians the flexibility to report on the activities and measures that most accurately demonstrate the performance of their practice.
Advanced APM Pathway
Under the Advanced APM pathway, clinicians can earn favorable fixed financial rewards by taking on more risk relating to patient outcomes. Clinicians who participate in an Advanced APM have the ability to earn an incentive payment bonus by going further in enhancing patient care as well as taking on additional risk. A five percent incentive payment bonus in 2019 is slated for Advanced APM participation in 2017.
Which MACRA Pathway Should You Take?
To get started, clinicians opting for MIPS can choose one of three tracks, beginning with a “test run,” which allows a choice of reporting one measure in the quality performance category, one activity in the improvement activities category or required measures of the advancing care information. For those who choose to do more, the second “Participating” category challenges clinicians to report a minimum 90-day period on more than one quality measure, more than one improvement activity or more than the required measures in the advancing care information. While the adjustment amount is still unclear, a possible nominal incentive may be provided at this level.
For high achievers who are willing to go “all in,” the third option requires reporting on all requirements for a full, 90-day period – and ideally a full calendar year. MIPS-eligible clinicians who are exceptional performers may receive an additional positive adjustment.
For eligible clinicians who already have a certain percentage of patients or payments channeled through an Advanced APM, this may be the best option. As a qualifying professional (QP), eligible clinicians will receive a five percent incentive payment per year beginning in 2019 through 2024. Those who participate in multiple Advanced APMs, but don’t achieve QP status in any single entity, may be considered based on the combined participation.
Rolling with Change
Like all of health care, MACRA is expected to evolve, as is evidenced by recent changes, including increased support for small and independent practices and growing momentum for Advanced APMs through potential new opportunities such as the Medicare ACO Track 1+. Building around a flexible, pick-your-own-pace option ensures a strong start, as well as connecting statutory domains into one, unified program that supports clinician-driven quality improvement.
The good news is that CMS estimates the more than 90 percent of MIPS-eligible clinicians will receive a positive or neutral MIPS payment adjustment in the transition year, including 80 percent of those in small and solo practices with one to nine physicians.
nThrive will help ensure that your organization is prepared for MACRA and beyond. From MIPS reporting services and MACRA education, to performance assessments, practice improvement and program transformation consulting, our MACRA Management Solution will empower you to thrive in an increasingly value-based incentive world. For more information, contact us at solutions@nThrive.com
To view the nThrive webinar titled, "Are you positioned to shine or fade under MACRA?" click here.