Ready or Not, MACRA Implementation Has Begun

Despite varying levels of readiness to participate in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program, the window for eligible clinicians to begin reporting data opens in January 2018. Recognizing that many practices are still building the infrastructure to participate fully in MACRA, the Centers for Medicare & Medicaid Services (CMS) has responded with changes for the second year of the program.

These updates to the 2018 Quality Payment Program aim to simplify reporting requirements and provide greater flexibility for eligible small, independent and rural providers. By raising the low-volume threshold, about 200,000 more clinicians will be excluded from MACRA’s Merit-Based Incentive Payment System (MIPS) in 2018.

Eligible clinicians will participate under one of two Quality Payment Programs: MIPS or Advanced Alternative Payment Model (APM), with most providers being placed in MIPS in the first two years of the program.

Under MIPS, CMS will assess providers on their performance across four areas in 2018: Quality, Cost, Improvement Activities and Advancing Care Information. Providers will receive a positive, negative or neutral payment adjustment based on their performance.

Specialty practices should focus the majority of their attention on the Quality category, as it represents 50 percent of the overall MIPS score in 2018. This performance category is the toughest and most challenging because the reporting requirements are complicated. Eligible clinicians have a menu of 275 quality metrics. Practices must report on six Quality measures, including one outcome measure.

The following considerations will help specialty practices prepare for MACRA’s reporting requirements:

Pick Your Pace in 2017

Many practices have participated in programs like the Physician Quality Reporting System (PQRS) and Meaningful Use (MU) and are comfortable collecting and reporting performance measures. Others may not be as prepared if they didn’t participate in these initiatives. Because practices have varying levels of reporting capabilities, CMS offers three paths into the mandatory new program from which practices can choose:

• Test: Test the program and submit a minimum amount of 2017 data to potentially avoid a penalty in 2019.
• Partial Participation: Report 90 days of 2017 data to avoid a negative payment or earn a small positive payment adjustment. Practices participating in this option should have started recording data in October.
• Full Participation: Submit a full year of 2017 data to CMS to earn a moderate positive payment adjustment.

Clinicians who do not report any 2017 data are subject to a four percent penalty in 2019. It is estimated that the average 2019 financial costs for nonparticipation in 2017, now that Part B drugs are affected under the 2018 Final Rule, will be approximately $74,680 per physician. This is based on the latest InfoDive¹ benchmarks from August 2017, which contain financial data for 450 physicians.

Looking forward, 2018 is still considered a transitional year of MIPS reporting. Practices will retain some flexibility regarding the reporting periods; 90 days for the Advancing Care Information (ACI) and Improvement Activities categories and a full year for Quality and Cost is required. 

Evaluate Your EHR

The updated rule for MACRA encourages the use of 2015 edition of certified EHRs, but allows for the 2014 edition, giving providers another year to make the transition. If practices use a 2015 edition of a certified EHR in 2018, they will receive bonus points for doing so. To evaluate EHR readiness to perform under MACRA, organizations should ask certain questions of their EHR vendor, such as:

• Can I collect and report performance data directly from the EHR to CMS?
• If so, which measures are available to me?
• Within the software, how do I assess what my performance rate is?
• How do I improve, if I need to, on any particular measure?
• How can I leverage the practice’s MU participation to optimize its ACI score?

If the EHR does not yet have the functionality needed for MIPS reporting, the practice will need to work with the vendor to upgrade or modify the system.

Choose Your Measures Wisely

There are other considerations in choosing performance measures. Practices can eliminate specialty-specific measures that are not applicable to them. For example, what’s right for orthopedics may not resonate for oncology practices. Also take into consideration improvement and quality activity measures where the practice has historically performed well. Consider choosing measures reported under previous legacy programs in order to avoid unnecessary compliance burden.

Practices should be aware that clinicians are not scored only against other specialists. Instead, a measure’s scoring is based on benchmarks set during previous performance years from the data reported by all clinicians who successfully reported on that measure. Depending upon where the benchmark falls for the measure, deciles are created as a point system, and every Quality measure will be scored differently.

Review Historical Data

To predict a practice’s performance under MIPS, examine existing performance metrics under PQRS and MU. In addition, take a look at the organization’s Quality Resource and Utilization Report, available on the CMS website. The utilization data will bring clarity to how the practice is measured from both a total cost and an episode cost perspective.

 Recent performance under the legacy programs is a good indicator of where the practice stands today—and what it needs to do to improve.

Determine Your Path Forward

The era of value-based reimbursement has begun. For long-term success, practices will require dedicated expertise to navigate MACRA’s complexities and keep abreast of changing regulations. Having a dedicated MACRA subject matter expert to develop policies and procedures, standardized workflows and a book of evidence is critical. Practices must decide whether to allocate the expertise in-house or work with a partner to delegate that responsibility.

Organizations should take advantage of MACRA’s extended transition period through 2018 to understand the program and make thoughtful practice changes in preparation for full participation. Those who position themselves well now are poised to be positive performers in the later years.

You can access additional information and resources about MACRA and MIPS at asco.org/macra or qpp.cms.gov. To learn how IntrinsiQ Specialty Solutions  can help your practice transform and succeed under MACRA, click here or call 877-570-8721 x2.  

^{1. InfoDive Business Analytics, ION Specialty Solutions, a part of AmerisourceBergen}