After much anticipation and speculation throughout 2016, MACRA is full speed ahead in 2017. But with the final rule, the ability to pick your pace allows participants some breathing room, not only to avoid penalties, but also to drive toward bonuses based on performance. Below are the crucial points to understand and leverage in order to be in control of how MACRA will impact you during this transition year.
For all healthcare systems, large and small, you should identify a MACRA initiative team of key leaders to head your organization’s transition. Once you have your team in place, these items should be first on the agenda:
- Make sure that you are able to report at least 90 days of data. Since 2017 is a transition year, the Centers for Medicaid and Medicare Services (CMS) only require that eligible clinicians report on the three performance categories for a consecutive 90-day period. While you do want to track data for the full year, you only need to submit data for the “best” 90-day period and can still achieve a maximum score for each performance category. Remember that medical groups can also omit data from certain eligible clinicians for the advancing care information category, for instance.
- Review your current data submission methods. While MACRA provides several methods to report each performance category, it is important to keep administrative costs in mind when evaluating your current reporting methods. For each performance category, CMS will only allow one submission mechanism. Don’t overlook public health registry reporting, which can help your scoring within specific categories like Advancing Care information.
- Identify current vendors, and determine if there is a way to consolidate your reporting. Similar to the point above, CMS expects the administrative burden will be minimized if organizations try to streamline their vendors. Since the Merit-based Incentive Payment System (MIPS) leverages many programs already in existence – VM, PQRS, and Meaningful Use (MU) - organizations should reference what measures will be carried over into the MACRA environment. CMS recommends participants use the same reporting mechanisms for ACI/CPIA that they already use for Quality.
- An important date to keep in mind is June 30, 2017. This date represents the deadline for groups to register with CMS and to also register for the CAHPS for MIPS survey as a quality measure for reporting. Your internal MACRA initiative team will have to identify all of the eligible clinicians that are currently working at your facility.
- Above all else, report something… anything! Even though CMS has made 2017 a transition year and softened some of the penalties, doing nothing still results in a 4 percent reduction in 2019 payments. So, reporting on just one measure prevents a penalty. Report on more measures across performance categories, for at least 90 consecutive days, to receive potential positive adjustments.
- Special note: MU and PQRS reporting is still active in the 2017 timeframe. Report your MU and PQRS reporting data as you have been doing because this does yield Medicare Part B reimbursement. In the meantime, you can also use this to map the MU and PQRS data to the MIPS ACI and Quality categories respectively. This will allow you to provide all three reporting data sets (MU, PQRS & MIPS) in 2017 in order to ensure a shot at higher reimbursement. The MU/PQRS will provide a reimbursement bump now and in 2018 and then the QPP-MIPS reporting can provide another bump in 2019.
CMS has stated that they are open to comments and feedback regarding MACRA for years 2018 and beyond. While 2017 is a transition year, much of the foundation is already present. In order to be successful under MACRA, health systems will need to dedicate sufficient resources to the transition and collaborate across the entire organization.
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