On Wednesday, April 27, CMS released the proposed rule for the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The almost 1,000-page, overly complex rule presents some major changes in the way physicians will be measured for quality of care and information technology use. Physicians are not only confused, but still feel a great deal of frustration and despair. We will continue to update you on time frames and take a closer look at the major components of MACRA, as we watch closely for comments from medical organizations and clinician practices.
According to CMS, MACRA repeals the Medicare sustainable growth rate methodology, “rewarding health care providers for giving better care, not just more care,” they stated in a recent CMS blog post. Their goal is to streamline the existing quality reporting programs – which they describe as a “patchwork system of Medicare reporting programs” – into one new system that will allow clinicians to choose from two paths (MIPS and APMs) that link quality to payments. The law is also intended to increase physician flexibility; clinicians can choose measures and activities based on the care they provide.
The new categories of measurement will consolidate PQRS, Physician Value-Based Payment Modifier and the Medicare Electronic Health Record (EHR) Incentive Program. Medicare will begin taking statistics on certain treatments and outcomes now and accumulating data on all physicians in 2017. Medicare will begin payment (or penalization) under this new, value-based system in 2019.
- Physicians can attest under Merit-based Incentive Payment System (MIPS) or Alternative Payment Model (APMs), though most physicians will participate in the Quality payment Program through MIPS.
- Physicians are not the only practitioners covered by MIPS. Physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetics and groups that include these types of clinicians are all MIPS-eligible.
- Meaningful Use and the EHR Incentive Programs will not disappear. Under MIPS, clinicians will be paid for providing high-value care through success in these four categories:
- Quality: This includes six measures from many options, according to specialty and practice. This category will make up 50 percent of your total score in the first year.
- Advancing Care Information: Meaningful Use and the EHR Incentive Programs will be folded into this category. Clinicians will report customizable measures that reflect how they use technology in their day-to-day practice, with an emphasis on interoperability. The idea is that this will not be a one-size-fits all requirement and redundancies in quality reporting will be eliminated. Your score in this category will count for 25 percent of your total score.
- Clinical Practice Improvement Activities: This category makes up 15 percent of the total score in the first year and will reward improvements in clinical practice, like shifting focus to care coordination, beneficiary engagement and patient safety. More than 90 options of activities will be available for clinicians to choose from.
- Cost: The score of this category (10 percent of total score) would be based on Medicare claims so it will not require any actual reporting from clinicians. It would use 40 episode-specific measures to account for differences among specialties.
- Only certain Alternative Payment Models (APMs) and Advanced APMs will be considered an “eligible APM.” Some participating providers may receive a lump-sum incentive payment or higher annual payments. These include the Next Generation ACO model, the new Comprehensive Primary Care Plus (CPC+) model (more on this in a later blog), Medicare Shared Savings Program Tracks 2 and 3, the Oncology Care Model with two-sided risk and Comprehensive ESRD Care).
- CMS is accepting comments and feedback on the proposal until June 27, 2016.
We want to hear your initial thoughts on the rule. Let us know what you think.