CMS’ Proposed Rule for MACRA 2018: Six Changes You Need to Know

By Aaron Turner-Phifer, Vice President of Government Relations and Policy on Jun 26, 2017 5:00:55 PM

CMS continues to ease administrative burdens for physicians as the “slow ramp-up” of the Quality Payment Program continues in 2018, according to the agency’s proposed rule for MACRA’s 2018 Quality Payment Program.

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The agency will continue its “pick your pace” approach for data reporting and expand the pool of physicians who would be exempt from mandatory participation.

“We've heard the concerns that too many quality programs, technology requirements and measures get between the doctor and the patient,” CMS Administrator Seema Verma says in a news release. “That's why we're taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork.”

Comments on the proposed rule are due by August 21. The final rule is expected to be released sometime this fall.

Among some of CMS’ most significant proposed changes:

  • The low-volume threshold gets another increase. CMS proposes elevating the dollar threshold for MACRA exemption from $30,000 in Medicare Part B allowed charges or 100 Medicare Part B patients, to $90,000 or 200 patients. CMS will also add a “significant hardship exception” from the “Advancing Care Information Performance” category.
  • Solo and small-practice physicians can participate by joining “virtual groups.” Physicians can combine their administrative costs by working with other docs in “virtual groups” of 10 or fewer physicians to participate in MIPS. Echoing URAC’s previous comments, CMS notes in the Fact Sheet released with the proposed rule, “Our goal is to make it as easy as possible for virtual groups to form no matter where the group members are located or what their medical specialties are.”
  • Credit for serving medically complex patients. CMS will add “bonus points” to the MIPS scores of clinicians who care for complex patients, are part of practice with 15 or fewer clinicians or who exclusively use the 2015 Edition Certified EHR Technology.
  • Adjusted scoring: In a departure from previous guidance, CMS will continue to heavily weight the Quality Category as part of the MIPS composite score. Specifically, CMS proposes the following weights for the 2018 performance year:
  • Quality: 60 percent
  • Advancing Care Information: 25 percent
  • Improvement Activities: 15 percent
  • Cost: 0 percent
  • Big increases in the number of Qualifying Advanced Alternative Payment Model (APM) Participants (QPs): CMS estimates that 180,000 to 245,000 clinicians may become QPs for payment year 2020. That’s up from the 70,000 to 120,000 estimated for 2017.
  • Adding an “All-Payer Combination” option: Beginning in 2019, a clinician can become a QP by participating in an Advanced APM with CMS, as well as an “Other Payer” Advanced APM. CMS also proposes tweaking part of the qualifying criteria for “Other Payer” Advanced APMs by requiring APM Entities to bear more than nominal financial risk if actual expenditures exceed expected aggregate expenditures; or be a Medicaid Medical Home. “Other Payer” includes a clinician’s at-risk payment arrangements with Medicare Advantage, Medicaid, and commercial insurers.

One way to ensure your organization achieves the maximum score under the MIPS Improvement Activities category is to pursue certification as a Patient-Centered Medical Home. URAC's program  not only meets requirements under MIPS but is designed to encourage the organizational development in a manner consistent with MACRA’s Alternative Payment Models. URAC is among only a handful of accrediting agencies recognized by CMS for PCMH certification.

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Aaron Turner-Phifer, Vice President of Government Relations and Policy

Written by Aaron Turner-Phifer, Vice President of Government Relations and Policy

Aaron Turner-Phifer has nearly a decade of experience advising and crafting public policy at the federal, state, and local levels. He has experience working on healthcare quality initiatives and public policy that impacts Medicare, Medicaid, and Health Insurance Marketplace enrollees. He is an expert political and policy analyst with a unique understanding of the intricacies associated with the development of health care policy. He is currently the Vice President of Government Relations and Policy at URAC in Washington D.C and is pursuing his Master’s Degree in Health Administration from George Washington University.

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