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MIPS Performance Category Weightings – MACRA Monday

Posted on January 16, 2017 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.

We’re going to keep this post short and sweet since it’s a holiday. However, we wanted to keep going with our regular MACRA Monday series. As we start to talk about the details of MIPS, the key change in the MACRA final was removal of the “Cost” category from MIPS. Ok, it wasn’t really removed. It’s still apart of MIPS, but it doesn’t influence the payment adjustment that you’ll receive. For those following along at home, the cost performance category in MIPS was a replacement of the Value Based Reimbursement Modifier.

Here’s the full breakdown of the 4 MIPS Performance Categories and how much weight each category will get in determining your MIPS Composite Score:

As a reminder, the Quality category replaces the old PQRS program. The Improvement Activities category is a new category. The Advancing Care Information category is the meaningful use replacement. We already mentioned that the Cost category is a replacement of the Value Based Reimbursement program.

Looking at the weights above, if you’re participating in PQRS, then MIPS is not going to be an issue for you. If you’ve been doing PQRS and Meaningful Use, then you’re well positioned to get access to the extra incentives available under MIPS. Although, remember that the MIPS incentives are subject to budget neutrality.

That’s the basic overview of the MIPS categories. Next week we’ll start diving into more details on each category.

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

Should Physicians “Just Say No” to MACRA? – MACRA Monday

Posted on January 9, 2017 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.

We’d planned to start diving into MIPS this week, but I couldn’t resist commenting on a post I saw on Medical Economics where a physician makes the case that physicians should just say “No” to MACRA. The opening paragraph describes the challenges of MACRA (and its meaningful use predecessor) pretty well:

I can’t recall the exact moment I crossed over from believer in today’s version of the healthcare quality movement to skeptic. Perhaps it was when the office trash would fill with clinical summaries the staff dutifully handed out to patients to satisfy a “meaningless use” measure. Or maybe it was trying to convince a 75-year-old Mrs. Davis that we would really appreciate it if she logged on to our electronic health record (EHR) using the patient portal. To do what, she asked? I stared back at her blankly.

It’s easy to make the case that some of the meaningful use requirements are meaningless. The same could be said for MACRA. That’s particularly true if you look at specialty specific instances where certain requirements made no sense to specific specialties. In other cases, the concept is good, but the execution is poor. For example, the concept of giving patients access to their health information is good, but it was poorly executed. Providing a clinical summary after a visit doesn’t really get us there and yet that’s what doctors were required to do.

Long story short, I understand why many see meaningful use and now MACRA as a distraction and they should just say no to both. In fact, that’s the advice that the author above offers:

My advice to physicians operating in this climate is simple: Don’t participate. MACRA clearly is the law of the land, and while one may hope the implementation from a Trump-Price administration will have a much lighter touch than the Obama-Burwell administration, sustained resistance in the form of non-participation is a small but important message to send to policymakers.

It is true that opting out of MACRA would send a small message to policymakers. If doctors would opt completely out of Medicare to avoid the MACRA penalties, that would send an even stronger message. I hear some doctors talking about this as an option as well. Both actions would send a message if doctors did this in mass. The problem is this isn’t happening and I don’t think it will happen.

While it is easy for a well paid cardiologist to say in a blog post that doctors should just say no to MACRA, my experience is that the MACRA math is much more difficult for general medicine and other specialties that don’t get paid as much and have large Medicare populations. The 4% MACRA penalty is a significant penalty to many doctors and “just saying no” is a very challenging decision for them financially. In fact, I’ve talked to many that just don’t see it as an option.

The same is true for people opting out of Medicare or reducing their Medicare population so the penalties aren’t as damaging. Not only is Medicare a significant source of revenue for many practices, but opting out of Medicare would hurt many patients who would have challenge finding care without them. Indeed, choosing to accept the Medicare penalties is not as easy a decision as some like to make it seem.

If you believe MACRA will fail, then opting out wouldn’t be as hard to handle for a year at a 4 percent penalty. However, I don’t see a scenario where MACRA fails so badly that it goes away. In fact, given the budget neutral nature of the legislation and the MIPS Pick Your Pace changes, it’s easy to see how MACRA is going to be proclaimed as a successful program. It would take some really serious lobbying for MACRA to disappear and I don’t see the will in Washington to make this a reality.

Assuming MACRA sticks around, your initial 4% penalty will grow to 9%. That’s a big hit to the bottom line for many practices. Given the Pick Your Pace options and the fact that most are already doing many pieces of the MIPS program (PQRS and Meaningful Use), why would a practice just take the penalty on the chin when the penalty is easily avoided? Out of honor and principle?

In fact, if you want to minimize MACRA’s impact on your practice it might send a clearer message to Washington if everyone participated at the lowest Pick Your Pace (Test Pace) option as opposed to a few people opting out of MACRA completely. If a few people opt out of MACRA and take the penalties, that will just fuel the incentives of those that participate in MACRA. If the majority of doctors do the minimum required to avoid the penalties, then they’ll avoid the penalties and it will send a message to CMS that they need to continue at a slower pace. Plus, those that participate fully will only get a small increase because there aren’t enough penalties to pay them what MACRA could pay them.

I previously suggested that the best strategy for most practices would be to go and participate as much as possible in MIPS so that a practice doesn’t get behind. I still think getting behind is an important concept to consider when you evaluate your MACRA participation. However, given the budget neutral nature of MACRA and the way it minimizes the incentives for full participants, I’m ok with a practice that chooses to take MACRA slowly. I just think most practices with a reasonably sized Medicare population are a bit crazy to not at least avoid the MACRA penalties.

Feel free to send a small message by just saying no to MACRA, but don’t expect that strategy to achieve the goals you desire. In fact, all it will likely do is damage yourself and put you in a harder position to participate in MACRA in future years. Of course, if you’re a highly paid specialist and/or you have a small Medicare population, then you’re choice doesn’t matter much to you or them anyway.

I agree that we should make an effort to get government regulation out of the EHR world as much as possible. It’s stifled innovation, burnt out doctors, and commoditized EHR software. I dream for the day when doctors love technology because it helps them be better doctors as opposed to better medical billers and government hoop jumpers. However, “just saying no” to MACRA won’t get us there.

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

MACRA is Required by Law to Be Budget Neutral – What’s The Impact? – MACRA Monday

Posted on January 2, 2017 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.

In my last post on MIPS benefits and the “Pick Your Pace” options, I published an old slide which highlighted the potential positive and negative payment adjustments under MIPS. Thanks to Lynn Scheps from SRSsoft (she also wrote our previous Meaningful Use Monday series of blog posts), it was pointed out to me that there’s one big caveat to how much positive payment adjustment you’d receive under MIPS. I don’t know how I missed it on page 1282-1286 of the final rule. It was such an important point, that I wanted to dive into all the details in a MACRA Monday post of its own.

This all gets pretty technical, pretty quickly, but we’ll try to make this as simple to understand as possible. The core issue at hand is that the MACRA program has to be budget neutral. This means that the MACRA penalties have to offset any MACRA benefits that are paid to participants. Since Pick Your Pace has made it so very few practices will receive the 4% MACRA penalty, that means that there won’t be as big of a pool of incentives available to those who do participate in MACRA.

The math gets pretty complicated, but this chart illustrates how the adjustments you receive could be effected by the need to make the program budget neutral:

This chart is illustrative, but I also believe that it’s a decent representation of what’s likely to happen given the lack of MIPS penalties that will be assessed. If the chart is accurate, most MIPS participants will receive less than a 1% incentive and exceptional performers will be less then 2.4%. That’s quite a big difference between the 4% that was originally discussed.

Now remember that CMS was stuck in a tough position. They had a legal requirement to make it budget neutral. They could have continued with the 4% positive payment adjustment, but that would mean that a whole bunch of practices would get a 4% negative payment adjustment. Instead, they chose to do Pick Your Pace to give people a chance to avoid the penalties. Now those people are happy, but exceptional performers pay the price because there’s no budget to reward the exceptional performers.

At least this is how I read the legalese. If anyone has any other nuances I missed, please let us know in the comments. Next week we’ll start diving into more of the MIPS Categories and changes to the MIPS Composite Score.

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

MIPS Benefits and Pick Your Pace – MACRA Monday

Posted on December 19, 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 promised, we’re back with another MACRA Monday looking at the MIPS Pick Your Pace options. However, before we dive into Pick Your Pace, we want to take a second to look back at the details of the MIPS incentives and penalties that are available as well. This really didn’t change in the final rule, so it’s review for those who have been following MACRA Monday since the beginning.

If you remember from last week’s MACRA Monday post, what you do in 2017 will determine your MIPS payment adjustment in 2019. Assuming you perform at the top level, you can get a full 4% positive payment adjustment to your Medicare Part B reimbursement (Note: It was pointed out to me that the MACRA program has to be budget neutral, so while they can give up to a 4% positive payment adjustment, it won’t be a 4% positive payment adjustment if enough practices aren’t penalized. With Pick Your Pace, hardly anyone will be penalized. On page 1282-1286 of the final rule it highlights this and points out that with the budget neutrality scaling, the upward adjustment is estimated to be under 1% for the base and 2.4% for exceptional performers. Thanks Lynn Scheps for the clarification!). Of course, if you don’t participate in MIPS, you’ll get a 4% penalty. That scales up to 9% in 2022. There are some exceptional performance bonuses as well, but we’ll cover that in a future MACRA Monday.

In the MACRA final rule, CMS added a number of other ways for doctors to participate in MIPS. They call the various options Pick Your Pace since the provider can choose how much they want to participate in MIPS in 2017. Here are the 3 MIPS Pick Your Pace options (and the Advanced APM for completeness’ sake):

As is laid out above, you can fully participate in MIPS for the entire year and get the largest positive payment adjustment. You can report on 90 days and receive at least a small positive payment adjustment and up to the full positive payment adjustment. Or you can just submit something to MIPS and that will have you avoid the negative MIPS payment adjustment.

The “Test Pace” option as it’s listed above needs some further clarification. Basically, if you don’t want to fully participate in MIPS, but want to avoid the negative payment adjustment you can just do 1 quality measure, 1 improvement activity, or the required advancing care information measures.

Clear enough? Basically, in 2017 they’ve made it so pretty much everyone should be able to at least do the Test Pace portion of MIPS and avoid the 4% negative payment adjustment. I don’t know of any practices where this wouldn’t be a reasonable goal. However, is that the best approach for a practice? I think not.

If I were advising a practice today, I’d suggest they shoot for full MIPS participation in 2017. Assuming they do well, they’ll get the full 4% payment increase and even could qualify for bonus payments. If they fall a little short, then they should still easily qualify for the MIPS partial year option which will provide them a small positive payment adjustment. If they experience a disaster with their MIPS participation, then they will still avoid any penalties.

Why is this my suggested route? MACRA and MIPS aren’t going anywhere. Sure, they might go through various iterations and subtle changes, but the move to this kind of reporting is here to stay and even a Trump presidency isn’t likely going to change this. Plus, you don’t want to be behind the 8 ball in 2018 when the full MIPS requirements will be upon us (Remember my post about thinking about MACRA like med school). You don’t want to get so far behind that you can’t catch up. If that’s still not enough, many people believe that the commercial payers are going to follow suit. Those that have participated in MACRA will be better prepared when they do.

Those are the details on MIPS pick your pace. We may take next week off from MACRA Monday for the holidays, but the next week we’ll be diving into more of the details of MIPS and other changes to the MIPS Performance Categories.

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

Health IT End of Year Loose Ends

Posted on December 13, 2016 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

In that random scrap heap I refer to as my memory, I’ve compiled several items not worthy of a full post, but that keep nagging me for a mention. Here are the ones that’ve surfaced:

Patient Matching. Ideally, your doc should be able to pull your records from another system like pulling cash from an ATM. The hang up is doing patient matching, which is record sharing’s last mile problem. Patients don’t have a unique identifier, which means to make sure your records are really yours your doctor’s practice has to use several cumbersome workarounds.

The 21st Century Cures Act calls for GAO to study ONC’s approach to patient matching and determine if there’s a need for a standard set of data elements, etc. With luck, GAO will cut to the chase and address the need for a national patient ID.

fEMR. In 2014, I noted Team fEMR, which developed an open source EHR for medical teams working on short term – often crises — projects. I’m pleased to report the project and its leaders Sarah Diane Draugelis and Kevin Zurek are going strong and recently got a grant from the Pollination Project. Bravo.

What’s What. I live in DC, read the Washington Post daily etc., but if I want to know what’s up with HIT in Congress, etc., my first source is Politico’s Morning EHealth. Recommended.

Practice Fusion. Five years ago, I wrote a post that was my note to PF about why I couldn’t be one of their consultants anymore. Since then the post has garnered almost 30,000 hits and just keeps going. As pleased as I am at its longevity, I think it’s only fair to say that it’s pretty long in the tooth, so read it with that in mind.

Ancestry Health. A year ago September, I wrote about Ancestry.com’s beta site Ancestry Health. It lets families document your parents, grandparents, etc., and your medical histories, which can be quite helpful. It also promised to use your family’s depersonalized data for medical research. As an example, I set up King Agamemnon family’s tree. The site is still in beta, which I assume means it’s not going anywhere. Too bad. It’s a thoughtful and useful idea. I also do enjoy getting their occasional “Dear Agamemnon” emails.

Jibo. I’d love to see an AI personal assistant for PCPs, etc., to bring up related information during exams, capture new data, make appointments and prepare scripts. One AI solution that looked promising was Jibo. The bad news is that it keeps missing its beta ship date. However, investors are closing in on $100 million. Stay tuned.

 

MIPS Timeline and Eligibility – MACRA Monday

Posted on December 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.

In the MACRA final rule, the timeline for MIPS was largely the same. However, I think there was some confusion on the MIPS timeline. So, while this isn’t a change from the MACRA proposed rule, I thought it would be worth highlighting the MIPS timeline for those that will be participating in the MIPS part of MACRA.

This graphic is the most succinct illustration of the MIPS timeline I’ve seen:
mips-timeline

As a summary, data for MIPS will be collected during 2017. How much data needs to be collected depends on which “Pick Your Pace” option you choose (more details on this in a future post). You must submit your MIPS data by March 31st following the performance year. Then, the positive or negative payment adjustment will happen the year after. For example, the 2017 MIPS performance year will determine your Medicare adjustment that goes into effect in 2019.

There was a slight change in who is eligible for MIPS in the MACRA final rule that is going to have a big impact. First, let’s take a look at who is eligible for the MIPS program:
mips-elibility

As you’ll see, there isn’t really a change in which types of providers are eligible for MIPS. However, you do have to have $30,000 in Medicare Part B billing and 100 Medicare patients a year in order to be able to participate in MIPS. Currently this is done on a per provider basis. They’re still considering virtual groups in future years.

There are 3 exceptions for providers that aren’t eligible to participate in MIPS. The newly enrolled doctors and Advanced APMs participants is the same as it was in the final rule. However, the low-volume threshold exception now excludes you from participating in MIPS if you have less than $30,000 in Medicare Part B or see 100 or fewer Medicare Part B patients. That’s a change from the proposed rule.

Here’s the full outline of the 3 MIPS exemptions:
mips-exclusions

That’s a quick look at the MIPS Timeline and Eligibility from the MACRA final rule. Next week we’ll dive into the details for Pick Your Pace. That should help you make a determination for how your practice should approach MIPS in 2017.

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 Timeline – MACRA Monday

Posted on December 5, 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.

Last week we posted about the APM Expansion in MACRA and the new PTAC Committee. Today we’ll dive into the timelines for APMs. They can get pretty confusing, so hopefully after you read this post you’ll have a better idea on how the APM timelines work.

Before we dive into the timelines, I also wanted to make a quick note of the benefits related to participating in an APM. The APM benefits really didn’t change in the MACRA final rule so our previous post on Advanced APM incentives is still accurate as well.

As we noted before, participating as an advanced APM provides incentives on top of whatever rewards are part of your original APM agreement. Under MACRA, you just get an extra 5% bonus on top of your pre-MACRA rewards for being in an APM. Here are the 3 main benefits of participating as an advanced APM under MACRA:
advanced-apm-benefits

As far as reporting as an Advanced APM, CMS will take three “snapshots” on March 31, June 30, and August 31 in order to determine which eligible providers are eligible as an Advanced APM and meet the thresholds to become a Qualified APM participant.

Here’s the official timeline details from CMS:

cms-apm-determination-timeline

At point B, the snapshots are taken to determine eligibility and at point D in the graph above, eligible providers will be notified of their APM eligibility. Yes, this is a very compressed timeline, so it behooves you to get started early. Remember that if you don’t qualify as an Advanced APM, then you still have to participate in MIPS.

The timeline for paying the 5% reward for being part of a qualified Advanced APM is still 2019 for reporting year 2017. 2018 reporting year will determine payouts for 2020 and so forth. That’s no change from the proposed MACRA rule.

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

APM Expansion and New PTAC Committee – MACRA Monday

Posted on November 28, 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.

Most of the general details about APMs was changed in the final rule (See our previous post about APMs and whether you should take part in an APM or MIPS within MACRA). However, if you want to dive into the details of APMs, then check out this CMS webinar and slides that dive into the APM program. One thing that didn’t change much yet is the types of programs that counted as possible advanced APMs:

  • Shared Savings Program (Tracks 2 and 3)
  • Next Generation ACO Model
  • Comprehensive End Stage Renal Disease Care Model (Two-Sided Risk Arrangements)
  • Comprehensive Primary Care Plus (CPC+)
  • Oncology Care Model (OCM) (two-sided risk track)

However, as CMS mentioned previously, their goal is to get more and more people involved in the APM program. As part of that effort, a number of other programs are likely to be eligible as an advanced APM in 2018:

  • Comprehensive Care for Joint Replacement (CJR) Payment Model (CEHRT)
  • Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT)
  • ACO Track 1+
  • New Voluntary Bundled Payment Model
  • Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model)

In fact, some of these might even be available in 2017. The MACRA final rule also created a new committee called the PTAC (Physician-Focused Payment Model Technical Advisory Committee). This committee will accept suggestions on other programs that should be considered an advanced APM. Then, they make recommendations to the HHS secretary on which programs should be added as Advanced APMs.

All updates on programs that qualify as an Advanced APM will be available on the CMS Quality Payment Program (MACRA) website.

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

What Will Be Trump’s Impact on MACRA? – MACRA Monday

Posted on November 21, 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.

Next week we’ll be kicking off our weekly series of details from the MACRA Final Rule. However, before we start going through the changes and what you need to know about MACRA, I wanted to cover an important topic of concern for many practices. I’ve heard a lot of practices that are afraid of what they consider the uncertain future in the coming Trump presidency.

While I believe that healthcare could see significant impact from a Trump presidency, I don’t believe that MACRA will be impacted by the change in presidency. First, MACRA was as bipartisan as you could find in Washington DC. Even if Trump wanted to replace, modify, repeal MACRA, I can’t imagine it getting enough support in the senate and house. If this is true, Trump won’t even try to do anything with MACRA. Second, Trump has plenty of bigger fish to fry. When you look at the various priorities that Trump has said he has for his presidency, nothing indicates that MACRA will be anywhere near those priorities. Third, it’s hard for me to imagine that Trump would see a problem with the move to technology in healthcare.

What also is worth noting is that MACRA is separate from ACA (aka Obamacare) and even ARRA (the HITECH Act). I’ll leave the predictions for what will happen with ACA for other people. I have no doubt that ACA will be impacted by the change in presidency, but even if they did a full repeal of Obamacare (which looks like it’s impossible), MACRA will still remain and be in force. If MACRA was part of Obamacare, I’d have a different view, but since it’s not then I think MACRA will continue forward as planned.

Those of you hoping for MACRA to disappear due to the new president and those of you waiting for MACRA to change after the comment period is over are grasping at straws. Love it. Hate it. Feel however you may about MACRA, I really don’t see any scenario where MACRA is not part of the future of healthcare.

What do you think? If you disagree, I’d love to hear why in the comments. If you agree, I’d love to hear from you as well. With that view, we’ll be continuing MACRA Monday blog posts for the foreseeable future so that our readers are ready.

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

What the Final Rule Means for Small Practices – MACRA Monday

Posted on November 14, 2016 I Written By

This guest blog post by John Squire, President and COO of Amazing Charts, is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

With the long-awaited issuance of the MACRA Final Rule earlier this month, the Centers for Medicare and Medicaid Services (CMS) tried to soften the blow for small practices in the first year of the program. Depending on the 2017 data you submit by March 31, 2018, your 2019 Medicare payments will be adjusted up, down, or not at all. This flexible timeline casts a wide net and should get everyone to participate.

Here’s a breakdown of all the options for 2017, from opt-out to maximum bonus, open to a small practice using a 2014 Certified EHR Technology (CEHRT). As you’ll see the sections get longer as we progress since each stage becomes more complex.

Be excluded from Medicare’s Quality Payment Program
In the Final Rule, CMS increased the exclusion threshold from $10,000 or less in Medicare Part B allowed charges, to $30,000 or less in billings, or seeing fewer than 100 Medicare Part B patients during the 2017 calendar year.

CMS estimates that this change will exempt approximately 30 percent of eligible clinicians from the Quality Payment Program. If you fall below the threshold, CMS will automatically exclude you. If you don’t meet the exclusion criteria, keep reading.

Do nothing… and take a penalty
Unlike previous programs such as Meaningful Use, there is no opt out for MACRA. If you don’t meet the exclusion requirement above, you are subject to downward adjustments. The Merit-based Incentive Payment System (MIPS) is the most likely option for small practices.

MIPS has a scale of 100 points. If you don’t report on any 2017 data by March 31, 2018, you’ll earn zero points and receive a four percent downward adjustment on your Medicare payments in 2019. This penalty rises over time, becoming five percent in 2020, seven percent in 2021, and nine percent in 2022!

A small minority of providers might be willing to make this financial sacrifice, but the vast majority of small practices using CEHRT are more likely to take a few simple steps to avoid the penalty.

Test out for a neutral outcome
You can avoid a downward adjustment by reporting just one quality measure, attesting to one improvement activity, or attesting to the four required Advancing Care Information (ACI) measures (formerly Meaningful Use) – for any length of time period in the calendar year of 2017. You’ll earn three points and there will be no downward adjustment to your 2019 payments.

This is a no-brainer for most small practices. If you use a 2014 Certified EHR, you’re already doing many of these activities, such as e-Prescribing, today. Belong to a Health Information Exchange? You’ve just earned your three points.

Participate for a bonus
You can earn four to 100 points for the chance of a small, moderate, or high positive adjustment to your payments in 2019. Submit at least 90 days of data on more than the minimum (i.e. on two or more quality measures, two or more improvement activities or more than the required four advancing care information measures) to earn more than three points.

Basically, the more information you submit over the longer length of time translates to more points and the more points you earn, the larger a positive adjustment on your payments will be, up to the maximum of four percent.

To earn the most possible points, (1) report for a full year on at least six quality measures (or a measure set); (2) attest to improvement activities worth 20 or 40 points (depending on the geography, size and make up of your practice); and (3) attest to all four of the required ACI measures as well as the five optional ACI measures, plus the one bonus ACI measure. Every 2014 Certified EHR technology has the functionality to support all ten ACI measures.

It could be easier than you think
CMS allows you to get a bonus for ACI when you use 2014 CEHRT to complete one of 94 eligible activities from the eight improvement activities categories. These include telehealth services, care coordination, or any kind of population health management. It could be something as simple as setting a flag for regular check-ups for your Medicare/Medicaid dual-eligible patients. A complete list can be found at this excellent CMS resource: https://qpp.cms.gov/measures/ia.

Even better news: providers participating in a patient-centered certified medical home (PCMH) will automatically receive full credit for the practice improvement category of MIPS. Similarly, providers participating in an Advanced Alternative Payment Model (APM) like an accountable care organization (ACO) will receive 50 percent of the full score for the practice improvement category.

Don’t get complacent – start today
While the agency’s idea of implementing a transition period was necessary, providers in small practices can’t get complacent. The formula for success is going to change very quickly. January 1, 2018 brings the full-year reporting requirement on the expanded measures.  The quality measures will still be required and the cost measures (previously called “resource use”) are going to dial up.  The year 2022 is only six years away, so unless the provider prepares next year, they could start facing some rather significant penalties.

About John Squire
John Squire, President and COO of Amazing Charts, has more than 27 years of high tech industry experience, 15 of them in Health IT. Before joining Amazing Charts, John was Senior Director of Alliances and Cloud Strategy for Microsoft’s U.S. Health and Life Sciences Business Unit.

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