In the last blog, we covered the basics of the upcoming rule MACRA. Just like many other laws, MACRA too is facing a lot of criticism. This has a lot to do with the payment adjustment criteria and the small time window to adapt to it. Under MIPS, practices get adjusted payments based on their performances. Whether it will be positive or negative, that depends on the performance of the practice.
Why criticism for MACRA?
The biggest problem with MACRA implementation:
- Only eight months between NPRM and final rule implementation. Practices might not get a chance to understand MACRA, let alone adapt to it.
- MACRA will hurt small practices. CMS estimated that approximately 9 out of 10 solo practices (87% precisely) would most likely receive negative adjustments worth $300 million. 69.9% of practices with 2 to 9 individuals in them will be hit by negative adjustments of $279 million. Some speculate that MACRA will enforce the smaller practices to merge with larger organizations.
- The final rule is yet to come somewhere around October and November, which increase the uncertainty factor.
Latest Announcement brings relief
Andy Slavitt, the Acting Administrator of CMS, made an announcement on 8th September that CMS would provide practices with four options. These options will allow the practices to pick their own pace. He stated on his blog, “ensure that all physicians who participate in the program are not penalized in the first year.” The four options are:
- Test the Quality Payment Program: It allows the physicians to test the QPP by just reporting some quality and cost data (“some” is undefined as of now). This option has been designed to ensure that the physicians prepare themselves in the first year and are ready for broader participation in 2018 and 2019. If an Eligible Clinicians (EC) merely reports ‘some’ data, he/she would avoid negative adjustments.
- Participate for partial calendar year: EC can choose to participate in QPP for a period of 90 days or more. Their first performance period can begin on or after 1st January 2017. Participating through option will allow the physicians to qualify for small positive adjustments.
- Full calendar year participation: This option is for the practices that are ready to participate for a full calendar year. Their performance period will begin from 1st January 2017, and they would qualify for modest positive payment adjustments.
- Participate in Advance APMs: The law has allowed the practices to be a part of APMs such as Shared Savings track 2 or 3 instead of being reporting various data. If a practice is able to receive enough Medicare patients through APMs, then it would qualify for 5% incentive in 2019.
Key takeaways from the four options
- Eligible Clinicians can avoid any negative adjustments in 2019 under MACRA by simply ‘testing’ the Quality Payment Program (Option 1). However, there is no potential for positive payment adjustments either.
- If one opts for option two, he/she can begin reporting later in 2017. The reporting period has to be at least 90 days. While, in option three it has to be for a full year.
- If both second and third options provide positive adjustments then why should one consider the third option over second? Larger organizations with complex patients would need to smoothen their data to maximize quality scores and qualify for higher adjustments. The third option has a larger performance period and hence a greater amount of data is responsible for Composite Performance Score. The payment adjustments in the third option are higher than the second.
- All those who are struggling to get ready for MACRA or have not reported under PQRS should choose option 1.
MACRA is an elaborate and an incredibly complex law. To understand it and perform well in it will take some ‘getting used to.’ The performance period will start from 2017 and for some practitioners it’ll be right from 1st January, but the first payment adjustments will happen in 2019. During this long gap, Eligible Clinicians should be aware of their performance and what could be their possible savings, so that they get a chance to work on making their practice even better.
Since there will be a Composite Performance Score (CPS) to measure the performance of an EC, the best course of action would be to stay ahead of the curve. A value-based focus should be supplemented with the right tools that can not only assist individual physicians but also help larger organizations in tracking the drilled down performance at an aggregate level to a facility/provider level.
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