Since its passage with bipartisan support in 2015, the regulatory impact of the Medicare Access and CHIP Reauthorization Act (MACRA) is far-ranging. From repealing the Sustainable Growth Rate (SGR) formula that determined Medicare reimbursement rates to mandating new programs that establish new paths to pay physicians caring for Medicare Part B beneficiaries, MACRA’s reach is ambitious. All programs are administered by the Centers for Medicare and Medicaid Services (CMS).
Aside from the current political climate, potential legislative changes to the delivery models, and patient access to healthcare, the general consensus now is that MACRA is here to stay and with its corresponding rules on payment for value, physicians increasingly will be paid based on the outcomes of their care. Though these programs may be new, in reality, what has happened is more of a consolidation of previous programs physicians and healthcare systems had already been participating in.
In its simplest form, the new rules take the previous value-based payment programs and put them in what is now called the QPP – Quality Payment Program. The QPP creates two new reimbursement structures: the Merit-based Incentive Payments System (MIPS) and additional options for Alternative Payment Models (APMs). Upon a closer look of the QPP, specifically at MIPS, physicians will recognize systems and features they may had already been using, such as the Physician Quality Reporting System (PQRS), Meaningful Use (MU), Value Modifier (VM), and the Electronic Health Record (EHR) incentive programs — all are present to some degree in the MIPS version.
For the majority of solo and small practice physicians, it mostly will be the case that if eligible, they will need to comply with MIPS reporting requirements. And, if so, much of what MIPS outlines physicians and their practices have already been engaging in to some degree. So in many respects, what MACRA attempts to accomplish may quite likely already be present in your practice.
As a reminder, the reporting period for payment adjustment in 2019 began on January 1, 2017, and several options became available to provide physicians with the flexibility to “pick their pace” for the reporting program they wished to participate under this year. A very important date to keep in mind is October 2, 2017, as this marks the last day to complete a 90-day reporting cycle in 2017 to track and submit MIPS data to CMS.
Participating providers will receive positive, negative, or neutral adjustments to the base rate of their Medicare Part B payment that will increase each year starting in 2019 with +4 percent to -4 percent; 2020 with +5 percent to -5 percent; 2021 with +7 percent to -7 percent; and ending in 2022, when it will be capped at +9 percent to -9 percent. Each reporting physician or group will be scored based on the performance measures outlined in MIPS. For maximum success in attaining the highest score, each practice should select the best variables to measure to help reach a maximum score in each category.
A major topic of discussion during the formation of these rules was the question of providing support specifically to solo and small practice physicians. Toward this end, earlier this year CMS awarded $20 million to 11 organizations across the country for the first year of a five-year project. These community-based organizations will be tasked with providing on-the-ground training and education about the QPP.
Among those organizations, the Health Services Advisory Group (HSAG) was selected and awarded a grant by CMS to provide assistance to California physicians. With multiple tools such as an online library, a live help line, printed materials, webinars, and one-on-one assistance, physicians participating in MIPS will find help with identifying the quality measures best tailored and most point-effective for each individual practice— all free of charge. Finding a new path leading to the ultimate destination of maximum reimbursement will be a multi-pronged group effort.
For more details on available resources, CMS also has created a QPP-specific web page where physicians can begin their path by confirming their MIPS eligibility and, if eligible, contacting HSAG for assistance with compliance.