The following Insight was updated on 9/25/2017 to reflect CMS changes to MACRA.
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 team of key leaders to head your organization’s transition into value-driven growth to ensure success under MACRA. Once you have your team in place, these items should be first on the agenda for organizations remaining largely in fee-for-service and therefor subject to the Merit-based Incentive Payment System (MIPS):
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 as much of the year as possible, 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 MIPS leverages many programs already in existence—the Value-based Modifier (VM), Physician Quality Reporting System (PQRS), and the EHR Incentive Program (Meaningful Use)—organizations should reference what measures will be carried over into the MACRA environment.
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. Reporting on just one measure prevents a penalty. Reporting on more measures across performance categories, for at least 90 consecutive days, positions you to receive potential positive adjustments.
While 2017 has been deemed a transition year for MACRA, MIPS thresholds and data requirements will begin to increase in 2018. By 2019 avoiding the negative payment adjustment will become even tougher. In order to sustain success under MACRA, healthcare organizations will need to dedicate sufficient resources across their entire organizations, both to meet the requirements of MIPS and evaluate the system’s participation in Alternative Payment Models (APMs).