With the final MACRA rule released on Oct. 14, the industry is now getting the chance to dig into all of the details of this 2,300-page document, especially the act’s Quality Payment Program, which replaces the Sustainable Growth Rate formula with two tracks of reimbursement—the Advanced Alternative Payment Models (APMs) or Merit-based Incentive Payment System (MIPS).
“Folks are now in the process of getting their heads around what’s in the final rule and determining what they have to do to respond in 2017,” said Aaron Turner-Phifer, URAC’s director of government relations and policy. “The most important thing right now is for practices and clinicians to be engaging with their medical societies and educating themselves on the best path forward.”
More than 760,000 clinicians will be impacted by MACRA, yet despite the amount of attention it has received since its passage in April 2015, data shows physicians still don’t know much about it. A survey of 282 physicians conducted by Medscape in September found that 87.8 percent of respondents were very unfamiliar with the law. Only 2.1percent said they knew a lot about MACRA.
- Providers will get a chance to “pick their pace.” In finalizing the rule, CMS undertook a “listening tour” over several months with nearly 100,000 individuals and collected nearly 4,000 public comments. Its biggest takeaway, according to the agency, was the desire for flexibility, simplicity and support for small practices, and the ability to navigate changes at a pace that ensures success.
“The result was a ‘pick-your-own-pace’ approach that offers four options, ranging from doing a few basic reporting elements to avoid a negative payment adjustment all the way through fully participating in MIPS or an APM,” said Turner-Phifer. “CMS recognized that clinicians and practices are all starting at different points and CMS will allow practices to start at whatever place is most appropriate for them.”
Providers who are ready to start collecting performance data can do so Jan. 1, but others have until Oct. 2 to begin, with all performance data due by March 31, 2018, and the first payment adjustments going into effect Jan. 1, 2019.
- The cost category will not be in 2017 reporting requirements. The data providers must submit for MIPS falls into four categories: quality (replacing PQRS), improvement activities (new category), advancing care information (replacing meaningful use) and cost (replacing the value-based modifier).
But to help providers manage this transition, they will not be required to report in the cost category next year. “That more heavily weighs the quality measurement component so that providers can place their initial focus in 2017 on quality, advancing care and practice improvement,” said Turner-Phifer. “The plan calls for phasing in the cost piece for the 2018 reporting year.”
- Telehealth is noticeably absent. Quashie says the connected health community was initially excited by MACRA and its potential to elevate the value and importance of telehealth and remote monitoring. But in this final rule, there’s little mention of telehealth.
“There’s some disappointment in the community about how little connected health factored into the final MACRA rule,” Quashie said. That doesn’t mean that telehealth is off CMS’s radar, he said; in fact, the Department of Health and Human Services just issued a report to Congress on e-health and telemedicine. “But I think they’re just not fully ready to embrace it yet from a payment perspective. I think as we see greater use and greater success of telehealth outside the Medicare context, it’s going to put increasing pressure on the federal government to more fully embrace and cover services.”
- The low-volume threshold has been increased. The initial dollar threshold for MACRA exemption was defined as any eligible provider who billed $10,000 or less to Medicare each year, “but the concern was the dollar threshold was so low that it would apply to providers who would have a hard time meeting the requirements of MACRA and would be penalized despite minimal Medicare activity,” said Turner-Phifer. Instead, the threshold for compliance was raised to those providers with fewer than 100 Medicare patients per year, or less than $30,000 in billing.
- Certification gives providers a leg up. To navigate these coming changes, Turner-Phifer often advises providers to consider pursuing certification as a Patient-Centered Medical Home, elements of which satisfies MIPS requirements. URAC is one of only four accrediting agencies to be recognized by CMS for PCMH certification.
“Providers who are PCMH-certified by URAC not only get the full 15 percentage points for improvement activities, but they are also well-positioned to be successful in quality and advancing care information categories,” he said. “Going through the PCMH process is the best way to prepare and will instill the infrastructure, the operations and the foundational elements required to be successful in the future.”
Read more on this topic:
- Clinically Integrated Networks: A Framework for Clinical and Financial Success
- URAC's complete, detailed PCMH Certification Standards (PDF format, 101 pages)
- CMS’ Proposed Rule for MACRA 2018: Six Changes You Need to Know
- URAC's Provider Integration and Coordination Programs