Even if they don’t know it yet, physician practices are going to be scrambling in the next 14 months, thanks to the phase-in of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) regulations.
The problem is, half of U.S. physicians had not even heard of MACRA as of July, a Deloitte survey found. Another 32 percent had heard the name but knew nothing about the requirements. That means that just 18 percent had any clue about the requirements of the law, which replaces the widely reviled Medicare Sustainable Growth Rate payment formula.
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“Providers need education,” said Tom Lee, founder and CEO of SA Ignite, a Chicago-based vendor of cloud-based back-office automation for healthcare providers in value-based reimbursement programs. “It’s a whole new ballgame.”
The Centers for Medicare and Medicaid Services did not finalize the MACRA implementation rule until the middle of last month, and even then, CMS took the unusual step of opening a 60-day comment period on a final rule. Plus, the rule is nearly 2,400 pages long.
Fortunately, CMS did announce some leniency before the final rule even came out, offering a series of “pick your pace” options for taking part in the new MACRA Quality Payment Program in 2017. But that is just for next year.
The Quality Payment Program contains two pathways: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models — including the next generation of Accountable Care Organizations. Providers that don’t submit any quality data to CMS in 2017 face Medicare penalties, though the “pick your pace” strategy allows for partial participation next year
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“The treadmill known as MIPS,” Lee said, “really starts to pick up speed in 2018.”
There are some ways to accelerate participation, though.
The MACRA rule treats hospital outpatient facilities as hospital-based place of service, so they can get a MIPS exclusion for submitting data toward Advancing Care Information compliance. Advanced Care Information is the new name for the federal health IT incentive program currently known as Meaningful Use.
Independent medical practices don’t have this option, though. For those with no more than nine clinicians or those in designated health professional shortage areas, CMS is allowing providers to form “virtual” medical groups for the purposes of MIPS quality reporting.
But there’s a controversial catch. CMS included virtual groups for 2017 in a proposed MACRA rule earlier this year, but pushed that back to 2018 in the final regulations. So solo and small practices, already in dire need of education and assistance with MACRA compliance, do not have the virtual option next year.
“You will see pretty good uptake of that in 2018,” Lee predicted.
CMS did leave open the possibility of reinstating virtual practices sooner, as it is one of the issues the agency asked for input on during the current comment period. Acting CMS Administrator Andy Slavitt did call MACRA a “living, breathing rule.”
CMS has projected that about 600,000 providers will participate in MIPS in some form in 2017, including 100,000 in an Advanced Alternative Payment Model. Lee noted that the final rule did relax the threshold for becoming an AAPM provider, reducing the downside financial risk from the earlier proposal.
But practices should tread carefully before joining an AAPM, he advised. “Choosing an alternative payment model is a huge deal,” Lee said. Contract lengths vary, but he is seeing most run 3-5 years, so practices will be locked in for a while.
Photo: Flickr user Richard Eriksson