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Modifications to the MACRA 2017 Reporting Period #PickYourPace – MACRA Monday

Posted on September 12, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

As we mentioned near the start of the MACRA Monday series, many were predicting a delay or at least a modification to the MACRA timeline. While we’re still waiting for the MACRA final rule to come out with the official changes, Andy Slavitt, Acting Administrator of CMS, has announced some of the changes that will be in the MACRA final rule. Here’s the introduction to why they’re making these changes to MACRA (or the Quality Payment Program as they like to call it now):

We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

It’s comforting to many to know that they hear doctors pleas for help with all the reporting. We’ll see if the changes in the MACRA final rule will be enough.

As part of the announcement, Andy Slavitt said that the MACRA and MIPS program will still begin on January 1, 2017 with payment adjustments (ie. incentives or penalties) being paid in 2019 like we’d noted before. However, CMS now plans to provide multiple options to eligible physicians and other clinicians to avoid the negative payment adjustments in 2019.

There will now be 4 options available:

Option 1 – Test the Quality Payment Program.
For this option, you just have to submit “some data” to the Quality Payment Program and you’ll avoid the negative payment adjustment. Basically, CMS just wants to make sure you’re connected and ready to participate in future years. While you won’t get a negative payment adjustment, you always won’t get a positive adjustment either. It will be interesting to see what the final rule defines as “some data.” I expect it will be pretty minimal.

Option 2 – Participate for part of the calendar year.
This option allows you to submit information for a reduced number of days in 2017. In other words, your performance period could start after January 1, 2017 and you could just do MIPS reporting for part of the year. This would qualify you for a small positive payment adjustment. I’ll be interested to see the details in the MACRA final rule which outlines how much smaller the payment adjustment will be and how it will be calculated.

Option 3 – Participate for the full calendar year.
This option is basically what’s in the MACRA proposed rule. You can take part for the full 2017 calendar year and potentially qualify for a modest positive payment adjustment. CMS suggests that many will be ready for this. We’ll see if that’s the case given the compressed timeline from when the final rule is published and the release cycles of EHR software companies.

Option 4 – Participate in an Advanced Alternative Payment Model in 2017.
It seems that participation in an Advanced APM is the same as the proposed rule. Of course, if you’re participating in an Advanced APM, then you avoid the penalties and don’t have to worry about MIPS. Nothing new there.

It’s no surprise that fewer penalties and looser requirements has been applauded by many in the healthcare community. It’s pretty rare that people complain about a loosening of government regulation and wish they would require more. Personally, I think the changes are a good thing. CMS will still be able to get data from organizations that participate for the full year. Hopefully, they’ll use that to guide any modifications for future years. However, they also aren’t penalizing those organizations who won’t be fully ready in 2017 because of the short timelines.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Advanced APM Requirements and Incentives – MACRA Monday

Posted on August 8, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Last week we looked at the MIPS and APM programs within MACRA and who will be participating in which program. Today we’ll briefly cover some of the specific requirements to participate in the APM program and the incentives you’ll receive if you are qualified and participate as an APM.

As mentioned before, most people won’t participate in an APM, but will participate in MIPS. This is particularly true because even if you’re part of an ACO or other value based care program you may or may not qualify as what they call an Advanced APM. Last week we listed the various APM definitions for who could be an APM, but we didn’t include this other criteria that is required for an APM to be considered an Advanced APM.

  • Use Certified EHR
  • Base Payment on Quality
  • Bears Financial Risk or Medical Home Model

If you want to dig into the advanced APM criteria, you can do so in the APM webinars that CMS did. They dive into the nitty gritty details of each, but we’ll pass on covering them here since they’ve done a great job and it only applies to a small group of our readers.

If you do not qualify as an advanced APM, then you’ll need to participate in MIPS, but you’ll do so with some favorable MIPS scoring.

APM Incentives
For those organizations that qualify as an Advanced APM, starting in 2019 you’ll receive up to a 5% bonus. This bonus will continue through 2024. In 2026, the bonus will be replaced with a higher fee schedule update.

Worth noting is that the MACRA APM program creates extra incentives for those who are already participating in one of the value based reimbursement programs. The MACRA APM program does nothing to change the current APM functions or rewards values. The 5% bonus will be on top of what was already planned for APMs.

Plan of Action
If you think that you might be part of an organization or program that will qualify as an APM, you’ll need to figure out if you qualify as an advanced APM. You should be able to consult your ACO or other APM organization to find out if you’re considered an advanced APM or not. The key question you’ll want to ask is, Am I considered an Advanced APM or not? Only Advanced APMs are excluded from MIPS.

That’s the short overview of the APM program. Next week we’ll start talking about the MIPS program.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.

MIPS or APMs … That Is The Question – MACRA Monday

Posted on August 1, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

As we outlined in the first entry of MACRA Monday, MACRA is broken down into two programs: APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System). The question your practice should be asking yourself is whether your practice will be participating in the MIPS or APM program. Practices will participate in one or the other, but not both.

Steve Sisko recently tweeted that CMS estimates only 4% of doctors will participate in MACRA as an APM. Regardless of the exact percentage, it’s clear that the majority of providers will need to worry about MIPS and won’t spend much time looking into the details of the APM program. As such, we’ll spend most of our MACRA Monday time diving into the details of MIPS and not APMs. However, in this post we will highlight what would make you qualify as an APM in case that applies to you.

Here’s CMS’ technical definition of who’s included in an APM:

  • CMS Innovation Center model
  • MSSP (Medicare Shared Savings Program)
  • Demonstration under the Health Care Quality Demonstration Program
  • Demonstration Required By Federal Law

In the CMS webinars, they offered this easier to understand list of who’s considered an advanced APM in 2017:

  • Shared Savings Program (Tracks 2 and 3)
  • Next Generation ACO Model
  • Comprehensive ESRD Care (CEC) (large dialysis organization agreement)
  • Comprehensive Primary Care Plus (CPC+)
  • Oncology Care Model (OCM) (two-sided risk track available in 2018)

Those are the details of who should be watching the APM program because they could be a participant. If you’re not participating in any of these programs, then you’ll not be taking part in the APM program. Next week we’ll dive into more details of other requirements to be what is considered an “Advanced APM”. Plus, we’ll dive into the benefits of participating as an advanced APM.

As I mentioned, we’ll be focusing most of our MACRA Monday series on the MIPS program, but it’s important that all practices spend time understanding the APM program even if you’re not going to be impacted by it in 2017. Why? CMS expects that while most practices will start their MACRA journey in the MIPS program, practices will transition to the APM program over time. How quickly that will happen and the process for switching programs will be interesting to watch. However, that’s why even MIPS participants should be keeping an eye on what’s happening with the APM program. It’s important to see the trends and shifts so your practice is ready.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.

What is MACRA? – MACRA Monday

Posted on July 25, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

As we mentioned at the end of last week, we’re excited to start a new series of blog posts called MACRA Monday. Over the next months (and possibly year(s)), each Monday we’ll step through the MACRA legislation and share the details of MACRA with you the reader. Many of you might have read our Meaningful Use Monday series which we wrote for a couple years leading up to meaningful use. This will be similar. You can find all the latest MACRA Monday posts here.

Before we begin, it’s worth mentioning that CMS has posted all the latest updates and details related to MACRA here. That’s largely where we’ll get our information for this series, but hopefully we can provide it to you in a more digestible format. Plus, we’ll add in our own opinions, views, and comments that will hopefully add even more value. At the end of the day, like it or not MACRA and value based care is heading your way. Knowing the details about it will better help you make decisions for the future of your practice.

In all of the CMS presentations on MACRA, they always start off with a slide that includes the same image. So, I thought it would be appropriate to start off MACRA Mondays with this image as well.
CMS Move to Value
No matter what happens to MACRA and other government programs, this slide illustrates the goals that CMS wants to achieve in healthcare. They want to shift the reimbursement from the current fee for service model into alternative payment models that pay for quality and value. CMS has said that they’ve already achieved their 30% goal for 2016. I think they’re being generous with their numbers, but that’s a topic for another day. Regardless of the details, CMS has clear goals to shift the healthcare system to a value based care model. MACRA is one major element of that effort.

What is MACRA?
The recent study by Deloitte found that a large portion of doctors are unaware of MACRA. Some had heard of MACRA, but didn’t know any more details. That’s a pretty scary thing considering MACRA will impact most ambulatory practices that participate in Medicare.

At the core of the MACRA legislation was two main goals: replace the Sustainable Growth Rate (SGR) and create a single framework – quality payment program. In the case of SGR, MACRA was the long-term solution to the annual “Doc Fix” or “SGR Fix” which literally shut down our government as congress debated how to address it. Along with replacing SGR, MACRA also streamlined multiple quality reporting programs into APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System).

We’ll talk in more detail in future MACRA Mondays about which programs ended up where and what they look like under MACRA. For now, we’ll just say that the new APM and MIPS programs consolidated programs such as PQRS, the Value Based Modifier, Meaningful Use (Officially called the Medicare EHR Incentive Program), ACOs, and PCMH to name a few.

Before I end this intro to MACRA, it’s worth noting that the MACRA rule is still only a proposed rule. So, everything we talk about now is talking about what’s part of the proposed rule. Certainly, any and all of this could change. The MACRA comment period ended June 27, 2016 and CMS received 3,710 formal comments (some of them extremely lengthy). However, given past changes to proposed rules (or lack thereof), I’d be surprised if anything changed too dramatically. We’ll talk more about possible changes in a future post.

We’ll be back next week with another MACRA Monday talking about who will be impacted by MACRA and whether your practice should be worried about participating in the APM or MIPS program.