This month, the Centers for Medicare & Medicaid Services (CMS) provided its latest update on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), a landmark piece of legislation that makes important changes to how Medicare pays physicians, who will now receive pay based on four categories: cost, quality, clinical practice improvement, and advancing care information. The update identified four new participation options for eligible Medicare physicians:
- Option 1: Test the Quality Payment Program. With this option, to make sure their systems are ready for more comprehensive participation in 2018 and 2019, physicians will just have to “submit some data to the Quality Payment Program, including data from after January 1, 2017” to “avoid a negative payment adjustment.”
- Option 2: Participate for part of the calendar year. This option allows physicians to submit their “Quality Payment Program information for a reduced number of days.” Theoretically, their practice could still receive a small positive payment adjustment even if their first performance period began after the start of the new year.
- Option 3: Participate for the full calendar year. If a practice is all set for the first of the year, they may “choose to submit Quality Payment Program information for a full calendar year” and qualify for a small positive payment adjustment.
- Option 4: Participate in an Advanced Alternative Payment Model in 2017. If a practice joins “an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017,” they won’t have to “report quality data and other information,” and might even qualify for a “5 percent incentive payment in 2019” if they “receive enough of (their) Medicare payments or see enough of (their) Medicare patients through” that model.
These are exciting developments, but what does a shift toward MACRA mean overall? To review, here are four essential things to keep in mind when considering MACRA:
- MACRA switches up the system. Through MACRA, providers will have several payment system options, including MIPS (Merit-based Incentive Payment System), a new variation of the current fee-for-service model, and new alternative payment models (APMs), like the Comprehensive Primary Care Plus model. Reimbursements are based on quality of care with several iterations doctors can choose from. To date, the final rules and timeline have not been published, and while the rules will be enforced by the government soon enough, there’s no time like the present to make the shift to the new process—or at least learn what it’s all about—as MACRA begins unrolling across the continuum.
- MACRA creates new arrangements. While the four new participation options will surely ease the transition, physicians will still have to quickly reorganize their goals with respect to MACRA. Deloitte's 2016 Survey of U.S. Physicians showed that most providers will have to make changes to their practice in order to comply with the new laws MACRA will introduce. Still, at the time of the survey, some physicians weren't even aware that MACRA had been passed into law. Fifty percent, in fact, didn’t even know what MACRA was. Additionally, small acquisition practices may have a harder time under the new MACRA arrangements. More than likely, these boutique practices will find themselves partnering up with healthcare systems as they adapt to changes. Ultimately, this is probably good news, as small networks will likely want to spread out so they can cover more area.
- MACRA affects everyone. In March 2016, it was reported by the peer-reviewed journal, Health Affairs, that physicians spend upwards of 15 hours per week processing quality metrics, which translates into an average cost of $40,000 per physician, per year. Or, to put it succinctly, an analytics burden. CMS is indeed trying to streamline MACRA's reporting process, but it still remains a strict requirement for all physicians who will now have to measure performance and quality. Given this, APM and MIPS providers will need to invest in technology and better business practices in order to avoid costly burdens. MACRA will encourage healthcare providers to become more flexible and to assess the kind of care they’re giving based on the new payment plans and regulation. This will result in higher quality care for patients and potentially big payouts for providers who comply. Clinicians and hospitals will begin to value those who can align quality measures in order to obtain for their group everything MACRA has to offer. However, those who don’t align to the new regulations will be put at financial risk, which will increase pressure on practices to consolidate and meet their new goals.
- Implementing MACRA now saves time later. With the introduction of the four new participation options, CMS continues to iron out all the final details for implementing MACRA, and this should stand as a stark reminder to us all that nothing is solidified until the program is officially rolled out. But that shouldn’t stop healthcare providers from doing their research and taking the steps to begin folding MACRA regulations into their routines for an easy transition when the time comes. Some health systems may decide to offer Medicare Advantage provider-sponsored plans in order to gain more control of their spending and avoid the new mandates. This might work for right now, but eventually, time will run out for this solution.
Embracing MACRA will help providers get ahead of the game, and we should all take the new participation options as evidence that CMS is conceding that MACRA is challenging but that the agency genuinely wants to be flexible amid an era of rapid change. Now it’s up to the rest of us to reciprocate that flexibility by staying current with the new regulations, doing our utmost to help realize the results that will soon benefit patients and providers alike, evaluating where we are with our current measures (PQRS, etc.), and working on those areas that need improvement.
Learn how the implementation of the Orion Health MSSP Management application marked a watershed moment in Scottsdale Health Partners’ MSSP journey, simplifying the reporting process, reducing the demands on their practices’ staff, and eliminating regulatory risk. Download the case study now!