In our earlier blogs on the MACRA Final Rule with Comment Period (Final Rule), we have been discussing a series of topics from the Final Rule, especially those with changes since the Proposed Rule earlier this year.
MACRA created the new Quality Payment Program (QPP), comprised of two avenues to reward delivery of high quality care: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). After the May 9, 2016 release of the Proposed Rule, the feedback on the imminence of the MIPS implementation was less than fully supportive. On September 8, CMS’ Acting Administrator, Andy Slavitt blogged about the agency’s new flexibility with respect to the implementation of MIPS, and the “Pick Your Pace” moniker made it to the Final Rule, published earlier this month.
CMS recognized that all practices will not approach the QPP in the same way, and therefore built some much needed flexibility into the Final Rule. For starters, CMS is treating 2017 as a transition year, making it more difficult for clinicians to receive the negative payment adjustments that represent the downside risk associated with MIPS and allowing time for clinicians and CMS to build their capabilities and gain valuable experience. Eligible clinicians will have four options when it comes to MIPS participation for the performance period starting in January 1, 2017, and an additional option related to Advanced APMs.
We often get the question, “what if I simply refuse to participate?” This worst-case scenario is addressed under the Pick Your Pace plan. MIPS eligible clinicians can choose to not report even a single measure or activity. If so, they will fall below the transition year threshold set by CMS and receive the full negative 4 percent adjustment.
However, those who choose to submit a minimum amount of information by choosing to report one measure in the quality performance category, a single activity in the improvement activities performance category, or report the required measures of the advancing care information performance category will reach the transition year threshold and avoid a negative MIPS payment adjustment.
Third, clinicians can decide to submit information for a partial year. These clinicians can choose to report at least 90 days of information but less than a full year during 2017 and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category. These clinicians may actually receive a positive MIPS payment adjustment.
Fourth, some clinicians may elect to report for a minimum of 90 days or all the way up to a full year and increase their chances to qualify for a positive MIPS adjustment. Those who are exceptional performers in MIPS will be eligible for additional reimbursement.
Lastly, it is expected that between 5 and 8 percent of clinicians will qualify to participate in Advanced APMs, qualifying them for a 5 percent bonus incentive payment in the first payment year, which is 2019.
Clearly, CMS is working to make MACRA more flexible, especially in 2017. Those who stand to reap the biggest gains are those who are successful in Advanced APMs. If you don’t fit that description, our advice is to take full advantage of CMS’ flexibility and begin planning to report as many quality, improvement activities, and advancing care performance measures as possible, and do so for at least 90 days in 2017. The latest date to begin reporting is October 2, 2017; the planning process should be top-of-mind by now, if not already underway.
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