The dust has begun to settle on the long-anticipated final rule for MACRA’s Quality Payment Program released by the Centers for Medicare and Medicaid Services (CMS) on October 14. After imbibing nearly 3,000 pages (and a few glasses of wine along the way), I’m ready to say without reservation that this is among the most complex and dense set of regulations this generation of healthcare providers has seen.
As they did previously with the Meaningful Use (MU), the American Medical Association and other provider groups are weighing in on the complexity and downstream impact of the new rules, in part intended to clear “the stench of MU” (as one CMS spokesperson put it) by consolidating MU and other existing programs. However, the Quality Payment Program (QPP) inherited many of the existing issues of MU, PQRS and the Value Modifier programs and added new layers of complexity around linking value-based reimbursement to the existing fee-for-service. (Irony clearly unintended.)
Nevertheless, the final rule ushers in the era of value-based reimbursement, tying a percentage of Medicare reimbursement to quality reporting, meaningful use of EHR, controlling cost and participation in alternative payment models.
Here are some need-to-know facts about the implementation of MACRA :
- The initial Quality Payment Program reporting period will begin January 1, 2017, as originally proposed in April 2016
- The QPP consists of two payment pathways – the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs)
- MIPS consolidates three existing value and quality programs: MU, PQRS, and the Value-based Modifier
- The final rule adds flexible part-year reporting options (dubbed “pick your pace”) to help practices transition to the QPP. However, a maximum penalty of -4% still exists for organizations who choose to report nothing in 2017
- The threshold for MIPS exemption in year one only is $30,000 in Medicare allowed charges or 100 patients (based on one year) – CMS estimates this will mean exemptions for 32.5 percent of Medicare clinicians, though not necessarily as many physicians
Next Steps: Formulate an Action Plan
Now is the time to act – the reporting period starts in two short months. While helpful, the pick-your-pace options necessitate an almost algorithmic decision process. Ask yourself if your practice is ready for the transition and if you have the knowledge you need to make decisions and take action.
Here are some preliminary questions for you to start thinking about:
- Do you have an in-house QPP expert?
- Are you MIPS-eligible in year 1?
- Assuming you are MIPS-eligible, do you participate in any of the advanced APMs outlined in the rule?
- Are you on track to successfully report MU and PQRS for 2016?
- Does your practice do any of the 93 Improvement Activities listed in the final rule?
- Are you a recognized patient-centered medical home or specialty practice?
- Are you currently monitoring cost using your Medicare QRUR and if so, how are you doing?
The answers to these questions will give you a starting sense of your readiness for the QPP. At the same time, if you don’t know the answers to these questions, it might be a good time to enlist outside help from your health IT partner, consultants or other qualified experts. Check out our MACRA page for more information.