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The MACRA Landscape: Risk and Reward? Part II
November 04, 2016
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The MACRA Landscape: Risk and Reward? Part I
November 02, 2016

The MACRA Landscape: Risk and Reward? Part I

Read on for a breakdown of what to expect from the near-final MACRA rule announced by CMS on October 14, 2016.
New MIPS exclusion threshold
For non–Advanced APM providers billing Medicare Part B to be excluded from MIPS reporting requirements altogether, the final rule massaged the low volume threshold to less than or equal to $30,000 in Part B allowed charges or less than or equal to 100 Medicare patients annually. First-time Medicare providers can also forego 2017 reporting.
 
Hospitals are not subject to MACRA, as they are in meaningful use. Federally qualified health center (FQHC) providers who bill through the Physician Fee Schedule are subject to MIPS, while those billing through the all-inclusion process are not. The same applies to rural health clinic (RHC) providers, as does the overall low volume threshold exemption for both.
 
Overall, CMS estimates that at least 592,000 ECs will be required to participate in MIPS in 2017, and that at least 70,000 will be eligible for the Advanced APM models.
 
Reporting options and payments
Overall, MIPS maintains the Quality, Improvement Activities (IA, formerly Clinical Practice Improvement Activities), Advancing Care Information (ACI, formerly Meaningful Use), and Cost Scoring pillars. But, not really. Again as a transition year, the cost category will not be reported or scored toward the 2019 payment adjustment. It will be included in 2018, as of now.
 
That leaves Quality (60% of score), IA (15% of score), and ACI (25% of score) for 2017 reporting, again with an ultimate reporting deadline of March 31, 2018, and there are a lot of ways to get there. Also, in line with the 90-day reporting options detailed below, ECs can start collecting and reporting data anytime between January 1, 2017, and October 2, 2017.
 
Last month, CMS announced it would start MACRA in 2017 and offer up 4 new reporting options to simplify the rollout. As translated in the rule:
  • Avoid a negative payment adjustment: Report 1 Quality measure, 1 aspect of the IA pillar, or report a minimum of 5 measures in ACI, and avoid a negative payment adjustment. (Choosing to simply forego MIPS in 2017 if a provider is eligible means a 4% negative payment adjustment in 2019.) With this option there is no required reporting timeline.
  • Possibly receive a positive payment adjustment: Report for 90 days and report more than 1 Quality measure, more than 1 IA or report more than the 5 minimum measures in ACI.
  • Full participation/qualify for positive payment adjustment: Report for 90 days or the entire calendar year.
    • Quality. Report 6 quality measures including 1 outcome measure, or 1 specialty-specific or subspecialty-specific measure set. Here reporting mechanisms also count. Overall, ECs can report to MACRA individually or as a group. Those reporting as a group and using the CMS web interface must report 15 quality measures for the entire year for maximum points. The use of a qualified clinical data registry (like Wellcentive’s) or other registries means less measures reporting. Groups qualifying as MIPS APMs would report through the APM entity per normal and would not need to report additionally for this category.
    • IA. Attest to 4 IAs for at least 90 days. (4 medium weight or 2 high-weight.)(Groups with less than 15 ECs or those in a rural or health professional shortage areas complete 1 high-weight or 2 medium weight activities.) ECs in certified patient-centered medical homes or an APM-designated medical home model automatically receive full credit in IA. Ditto MIPS APM ECs, such as those within MSSP Track 1 models or the oncology care model. ECs in any other APM receive half credit.
    • ACI. Report 5 measures for at least 90 days. Gain additional scoring for reporting additional measures.
  • Bonus payment and MIPS exemption: Report via the existing Advanced APM payment model on an annual basis. ECs in an Advanced APM really have less of a puzzle to put together. Essentially, little changes to how data has been historically compiled and reported. The 5% bonus payments are scheduled through 2025.
For increased or full participators, MIPS ECs can choose different 90-day periods to report data per scoring pillar. Also, MIPS ECs can receive extra positive payment adjustments for the first 6 years of MACRA by submitting extra measures beyond the bare minimum or the full participation levels.
 
Click here to read Part II.

 
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