The Centers for Medicare and Medicaid Services (CMS), on October 14, 2016, released the rule that finalizes the parameters of the Advanced Alternative Payment Models (APMs) and the Merit-Based Incentive Payment System (MIPS), which are collectively known as the Quality Payment Program (QPP). This final rule will implement the provisions of the Medicare Access and CHIP Reauthorization Act (MACRA), and will therefore soften several parameters of the MACRA regime.
The MACRA policies will come into effect in CY 2017. However, the provider performances during that year would yield payment consequences to them in CY 2019. Though the rule is final for the CY 2017, but it has a 60 day comment period.
Final Rule Highlights:
- CMS offered flexible reporting options for the CY 2017. However, medical groups should not delay implementation efforts, instead, they should take advantage of this on-ramp to set up for long term success.
- CMS made the on-ramp to the APM track, and thus downside risk, more accessible for providers.
- In the early years, quality will be the critical performance differentiator.
- The MIPS participant pool has shrunk, potentially making the competition fiercer than ever.
- Improvement activities have become easier than ever; therefore, there is no reason not to get full credit.
- Though cost is weighted at zero for the CY 2017, but it should not be ignored.
- There is added flexibility in Advancing Care Information (ACI), which makes it another easy win category.
MIPS Track Scoring
Providers that will choose MIPS track will earn a composite performance score that will be based on four categories:
- Quality of outcomes (50%): Familiar clinical quality measures, same as Physician Quality Reporting System (PQRS).
- Cost of outcomes (10%): Reporting is not necessary, because it is measured solely on the basis of a claim.
- Clinical Practice Improvement Activity (15%): It is a new category that focuses on better processes in nine areas. Every activity has “all or nothing” scale for scoring.
- Advancing Care Information/Use of Health IT (25%): It is the most complicated category, as there are three types of scores in this category.
The scoring done for these four categories will further translate into a 100-point scale MIPS score, which would translate into a reward or penalty. The penalty/incentive bar will move every year on the basis of national performance of participants. The more participants who do well, the lower will be the incentive, as the program has to remain budget neutral.
APM Track Working
Providers who choose the optional APM track will agree to higher potential reward and higher risk. This track is not a single model; rather, it is a category of payment models that provide financial benefit for achieving quality; share assumed risk; and require information sharing across care locations.
Only advanced APMs are eligible for MACRA. Some of them include: Next Generation Accountable Care Organizations (ACO), Medicare Shared Savings Program (MSSP) Track 2 and Track 3, Comprehensive Primary Care Plus (CPC+), an Organization Care Model available in 2018, and Comprehensive ESRD care Model (renal dialysis organizations). The omissions from the list include: Comprehensive Joint Replacement (CJR), MSSP Track 1, and Patient-Centered Medical Homes.
These models require the providers to bear more than a nominal financial risk. They also require less investment up front, and promise greater rewards on meeting certain milestones. To be successful, providers might need to create new organizational systems for financial and clinical management to manage quality.
Many details for the implementation of MACRA have yet to be finalized through federal rulemaking. However, for now, CMS has requested information from the public and is working with stakeholders from the physician community to make sure that each component is finalized with feedback from those whom it will effect.
The impact of MACRA will be unique to each provider. But, the first step is to understand the rule and how it might affect you. For more insights on the proposed rules for MACRA and MIPS and how it will impact your Medicare payments in 2017, attend this Webinar by expert speaker Jeanne J. Chamberlin, who is currently a Practice Management Consultant with MSOC Health. You will also get to understand the impact of MACRA and analyze the pros and cons of APM and MIPS.