By: Ben Regalado, contributing writer
After considering a delay to the start of the new MACRA payment reform initiatives, CMS recently announced it has decided instead to allow providers to determine the speed that they will be able to implement the new requirements, lessening the potential penalties (and benefits) in exchange for breathing room to begin full participation.
Most physicians, it is believed, will opt for the Merit-based Incentive Payment System (MIPS) methodology over the riskier, though more integrated, Alternative Payment Models (APM) such as Accountable Care Organizations (ACOs) and Patient Centered Medical Homes (PCMH). (That is approaching a record for number of acronyms in a sentence.) Although unstated, it is believed that the new “flexibilities” were made to give consideration to smaller practices who still wish to remain independent.
Although final regulations are not expected until November 1, the MIPS program is on track to begin January 1, 2017, with the impact on payments to be up to +/- 4% in 2019. Those providers who are ready - most likely medium sized to large practices - can jump right in through one of the two original options:
1. Begin with complete reporting on January 1, 2017, participating fully and potentially reaping the full reward.
2. Participate through an Advanced APM.
The new “flexibility” is found with two additional options. These options are graduated to allow for providers to ease into MIPS at a pace best suited for them, while keeping the incentives (or penalties) higher for those who are ready to begin. In these new options:
3. Eligible providers may elect to simply report any data to avoid a negative payment adjustment. This transitional approach is basically a “test the waters” approach to assure systems and process are ready to go for 2018 and 2019, or
4. Eligible providers may choose to report measures over a “reduced” number of days, meaning data reporting begins after January 1, creating an opportunity to earn at least a small bonus payment.
As reported on this site before <http://www.scghealth.com/news/take-on-mips-and-pqrs-from-searfoss>, meeting MIPS threshholds should not be an issue so long as practices are ready with their processes to meet the four aspects of MACRA MIPS reporting. Per CMS <http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html>, the relative achievements within these four pieces of the puzzle will be given various weights (to change over time), which then will be used to calculate an overall “score”. This score will then determine the amount of increase or decrease in payments that providers could see.
For 2017, eligible providers participating fully will need to focus on these objectives:
A. Reporting and meeting performance thresholds on 6 of more than 200 Quality measures (formerly “PQRS”) - 50% of year 1 score.
B. Cost Control (based on claims data) - 10% of year 1 score.
C. Reporting on participation in some of the more than 90 Clinical Practice Improvement activities - 15% of year 1 score.
D. Reporting on activities related to Advancing Care Information (formerly “Meaningful Use”) - 25% of year 1 score.
To be clear once again - this is not a delay like ICD-10. To avoid penalties you should plan to report quality data beginning at some point in 2017. Continue to watch this site for more information once the final rule is released.