In the previous installment of this two-part series, we considered how the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is the game-changer in the transformation of physician payment from fee-for-service to value-based payment. We further contemplated the fact that about 19 in 20 MACRA-affected providers will fall under the Merit-Based Incentive Payment System (MIPS), which consolidates the current Physician Quality Reporting Program (PQRS), Value-Based Payment Modifier (VM), and Meaningful Use (MU) programs into a single Quality Payment Program (QPP). We also pondered critical actions to take today to prepare for MACRA, one of which is identifying preferred MIPS metrics.
There should be among the great majority of providers a sense of urgency centered on MIPS readiness. This includes taking steps to maximize performance in controllable areas during the performance period, as this will affect the scores and related payment adjustments applicable to Eligible Professionals (EPs). This begins with an assessment of where the organization stands relative to the current Medicare quality and value programs by asking whether the organization is participating in PQRS, VM, and MU programs and to what extent the organization and its providers are successful in the programs.
Because the quality performance category makes up 50 percent of the composite score in the first year, shoring up quality reporting is one of the best ways to have an early impact on MIPS success. For example, CMS made available in April of this year the 2015 Mid-Year Quality and Resource Use Report (QRUR). The Mid-Year QRUR gives interim PQRS feedback and VM performance, which can be helpful in understating where potential weaknesses exist.
In the May 2016 MACRA Proposed Rule, CMS proposed quality performance category reporting to generally include a minimum of six measures, including at least one cross-cutting measure and one “high priority” measure. Bonus points are proposed for reporting additional high priority measures and for end-to-end electronic reporting of quality measures. MIPS-eligible clinicians and groups will select their measures either from among the list of individual quality measures or specialty-specific measure sets created by CMS. MIPS-eligible clinicians and organizations should begin now to think about the metrics that will be selected for quality performance reporting. Some of the important factors that should be considered in selecting quality performance measures include the following:
- Is there a specialty-specific measure set that is more applicable to our situation than individual measures?
- What are the measures with the highest current PQRS performance based on individual or group reporting?
- Do we have sufficient volume to meet the minimum caseload requirements for the selected measures?
- Do we have confidence that our HIT system is currently or will be sufficiently capable of capturing and reporting on quality data?
- How can we better educate our EPs about MIPS?
- What can be done in the coming months to improve performance in the selected measures, including adapting EP compensation to incentivize quality performance?
These are among many ways that organizations can begin to improve their MACRA preparedness. Other steps focus on resource use using cost data from the VM program data, advancing care information from MU reporting, and the new Clinical Practice Improvement Activities (CPIA) category, which focuses on care coordination, safety, and other measures.
Another of the keys to success with MACRA is to recognize the possibilities for disruption in the physician supply marketplace and be prepared for and capitalize on further consolidation. The Deloitte 2016 Survey of U.S. Health Care Physicians reports that both independent and employed physicians surveyed expect between one- and two-thirds of remaining independent physicians will consolidate in the next three years. This has the potential to translate into opportunities for hospitals to optimize physician networks and group practices to evaluate growth potential.
Acting now to recognize, evaluate, and plan for opportunities also includes partnering with financial and legal firms skilled in healthcare in general and MACRA, specifically.
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