Are you ready for MACRA changes?
The Medicare Access and Chip Reauthorization Act (MACRA) of 2015 was instrumental in eliminating the Sustainable Growth Rate (SGR) that was tied to Medicare Part B provider reimbursement for years. The good news is that through 2019, Medicare Part B payments will increase by .5% each year. The challenging news is that Medicare Part B providers have until 2019 to become educated with, and prepare for, the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).
At this time, CMS has provided information on their website, and several publications have had articles regarding the current rules for MIPS and APMs. The initial information emphasizes a change in payment from quantity to quality medical care. The current physician incentive payment systems, such as Physician Quality Reporting System (PQRS) and Meaningful Use (MU) will be “blended” as part of the MIPS criteria. MIPS will use January 1, 2017 through December 31, 2017 for the first performance period, and then this data will be applied towards payment beginning in 2019.
MIPS will consider the following criteria:
- Quality: This metric accounts for 50% of the total score in the first year. Quality replaces the PQRS and the quality measure of the Value Modified Program. Physicians would report on 6 measures versus 9 measures.
- Advancing Care Information: This metric accounts for 25% of the total score for the first year. Advancing Care Information replaces MU reporting. Physicians would report on how their electronic medical record helps with their day-to-day operations.
- Clinical Practice Improvement Activities: This metric accounts for 15% of the total score for the first year. This metric focuses on improving activities such as care coordination and patient safety.
- Cost: This metric accounts for 10% of the total score for the first year. The score will be based on the claims the physician submits.
MIPS payments will be “budget neutral”, meaning the positive, negative and neutral effect of the scores based on a “pot” of money for Medicare Part B payments. The MIPS reward (or penalty) will start in 2019 at 4%, and then gradually increase over a 3-year period:
- 2019 = 4%,
- 2020 = 5%,
- 2021 = 7%, and in
- 2022 and after = 9%.
APMs participation encompasses a financial risk to providers for providing coordinated, high quality care.
Physicians would be exempt from MIPS reporting requirements. Physicians would have to participate in an Accountable Care Organization (ACO), a Medical Home, or a Medicare Shared Savings Program. Physicians could receive a 5% lump sum bonus payment from 2019 to 2024 based on their success. A key requirement for APMs participation is that the physician must use an electronic medical record. In 2019 and 2020, the participation requirements for APMs are only for Medicare payments or patients; however, starting in 2021, the participation requirements may include non-Medicare payers and patients.
CMS is expected to release more rules regarding MIPS and APMs in June 2016.
Just as we survived the transition from ICD-9 to ICD-10, we will survive the transition to MIPS and APMs. Which payment method will be best for your practice? Becoming familiar with the advantages and disadvantages of MIPS versus APMs, will help the physician determine with program is best for their practice. There are numerous resources available at the www.cms.gov website, and we recommend your medical practice leadership continue to become more familiar with the MIPS and APMs features over the next several months.