On January 20, 2017, Donald Trump was sworn in as the 45th President of the United States. While change is inevitable under every new administration, this administration seems to have ushered in a distinctly different political environment due in part to a heightened uncertainty concerning health care policy.
As the new administration begins its second quarter, we are still waiting to see how the cards will fall; appointments are still being made that will provide a clearer glimpse into the future of health care policy. Among the many policies that are up for discussion, clinicians are questioning if or how the Medicare Access and Chip Reauthorization Act of 2015, MACRA, will be affected. Under MACRA’s Quality Payment Program, QPP, health care clinicians who render better care, not just more care, are rewarded through payment reimbursements upon meeting certain criteria. Per the Centers of Medicare and Medicare Services, CMS, MACRA is designed to “improve Medicare by helping [clinicians] focus on care quality and the one thing that matters most –making patients healthier.”
Health care policy experts believe any repeal or delay to MACRA is highly unlikely because it has strong bipartisan support; passing the House of Representatives with a 392 – 37 vote and the Senate with a 92 – 8 vote. As such, CMS will continue to forge ahead with these payment programs that tie physician pay to measured quality of care. Additionally, a repeal would result in negative budgetary repercussions to the QPP’s cost-saving framework, which is not something any administration would choose to undertake.
Moving to Value
Even if some MACRA QPP policies are modified, the move toward value-based care is not being reconsidered. nThrive recommends that health care organizations continue progressing toward value-based, population health care. But “progress” means different things to different health systems. Your organization needs to determine what level of engagement best aligns with your value-based reimbursement strategy, both in the near term and down the road. nThrive recommends that you consider the four levels of participation as outlined here.
Of the four ways to participate, CMS anticipates 83 to 90 percent of eligible clinicians will fall under one of the three Merit-based Incentive Payment System (MIPS) paths in 2017.
1. Test Pace Participation - MIPS Compliance
Participate in the QPP in 2017 complying with the most basic requirements, resulting in a zero percent Medicare Part B FFS payment adjustment in 2019.
The requirements for this path consist of:
- One Quality measure, or
- The five required Advancing Care Information measures, or
- One Improvement Activity
By partnering with a CMS registry, such as nThrive, your data will be seamlessly reported to CMS. Your organization will meet the reporting requirements and avoid a negative payment adjustment.
2. Partial Participation - The MIPS Reporting and Opportunity Monitoring
Participate in the QPP in 2017, exceeding the minimum requirements, resulting in a nominal positive payment adjustment.
If your organization has participated in quality reporting under the Physician Quality Reporting System (PQRS), it may be in your best interest to report with the goal of receiving a positive adjustment in mind. This path encourages more engagement with available measures and helps identify opportunities for improvement. This level requires 2017 reporting for a period of 90 continuous days and submitting the following:
- More than one Quality measure, or
- More than just the five required Advancing Care Information measures, or
- More than one Improvement Activity
3. Full Participation – Exceptional Performance Bonus
Participate in the QPP in 2017, exceeding the minimum requirements, resulting in a positive payment adjustment of up to 11 percent, including a 10 percent exceptional performance bonus.
This path puts your reporting entity in the best position to compete against other MIPS participants and prepare for both current and future reporting success. In addition to reporting and identifying opportunities for improvement, your organization must incorporate extensive education resources and would benefit from meaningful advisory services. This level requires 2017 reporting for a period of 90 continuous days and submitting the following:
- Six Quality measures, plus
- The five required Advancing Care Information base measures, plus
- Minimum of five Performance measures, plus
- Two to four Improvement Activities
nThrive will ensure you are positioned to compete for a piece of the $500M exceptional performance bonus allocation – a bonus of up to 10 percent of your Medicare Part B FFS reimbursements.
4. Alternative Payment Models (APMs) and Advanced APMs
An APM is a payment approach that motivates clinicians to provide the highest quality and most cost-effective care. Advanced APMs are a subset of APMs; successful participation with an Advanced APM under MACRA:
- Exempts clinicians from participating in the Merit-Based Incentive Payment System (MIPS)
- Qualifies clinicians to receive a 5% annual payment incentive for the first six years of MACRA (through the 2024 payment year)
Advanced APMs have reporting requirements similar to the MIPS, but the Advanced APM entity will, in general, manage the reporting process. There are several additional requirements that must be met by the Advanced APM entity, but overall, the data reporting requirements that affect clinicians include:
- Performance on a specified set of quality measures
- The Advanced APM’s level of electronic health record (EHR) use, including its members’ performance on the Advancing Care Information category of MIPS
- Activities that meet the general requirements of the MIPS Improvement Activities
- Any improvement activities that are integral to the Advanced APM structure
These are challenging, but important times in health care. As we move further toward value-driven care, whether it be through MACRA as we know it or a tweaked version, we do know there is consensus to continue moving away from fee-for-service by volume in favor of fee-for- value models.
nThrive offers years of experience with Medicare fee-for-service quality programs and is prepared to assist you. We will help you navigate value-based care by providing you with data-driven advisory services, education and analytics support that will best position you for success.
Visit our website to learn more about our MACRA Management Solution.