By Neil Simon, COO, Aprima Medical Software
Twitter: @AprimaMedEHR
Twitter: @neilasimon
When CMS decided recently to allow physician practices to delay compliance with the MACRA cost and quality program, it was as if a collective sigh of relief could be heard across the country. With the final rule on MACRA anticipated in November, less than two months before reporting was scheduled to start, the timing would have been too close for comfort.
While the reprieve was welcome—and wise—it’s still important to begin preparing now for what lies ahead. In some cases, that will mean making up for lost time. A recent Deloitte survey of 600 doctors around the country found that half weren’t even aware that the final MACRA rule, which follows CMS’s proposed rule issued in April, was coming.
According to the current plan, MACRA will use 2017 performance to determine 2019 awards and penalties. CMS, responding to Congressional pressure to offer flexibility, has laid out four options for 2017:
- Submit any data at all to avoid penalties (but forfeit rewards)
- Comply fully, but start later than January 1
- Comply fully starting on January 1
- Prove most business is in alternative payment models (APMs)
An Opportunity to Leverage Your EHR Data
While it may be tempting to delay complying with MACRA for as long as possible, practices that do are leaving money on the table. MACRA presents an excellent opportunity for physician groups to access significant rewards for high-quality, efficient care—and these rewards are not limited to large practices within accountable care organizations or large health systems. What’s more, every practice can likely leverage their existing investments in electronic health record (EHR) systems to reap these benefits.
For smaller practices, CMS took into consideration the added burden that the new regulations may pose. The agency has set aside $20 million a year to provide technical assistance via Quality Improvement Organizations (QIOs) and Regional Extension Centers (RECs) to practices with 15 or fewer eligible professionals. Priority will be given to practices in rural areas, health professional shortage areas, and medically underserved areas.
Another cause for relief is that this cost and quality program is not entirely new. MACRA consolidates and replaces a number of value-based reimbursement programs, including the Physician Quality Reporting System (PQRS), Meaningful Use (MU) and the Value-Based Payment Modifier.
How You Can Get on Track
MACRA includes two tracks – one for physician groups still largely operating in the fee-for-service realm, called the Merit-Based Incentive Payment System (MIPS); and those practices with the bulk of their business in alternative payment models (APM).
The APM track will allow practices to use the cost and quality measures dictated by their alternative payment contracts to satisfy CMS requirements, and enable those practices to earn up to 5 percent more than their current reimbursement rates. But the vast majority of practices, even those with some risk-sharing agreements, won’t meet the high bar CMS has set for the APM program. Complicating matters, practices seeking inclusion in the APM track won’t hear whether they’ve been accepted until 2018, after the first year of performance reporting.
So most groups should prepare to meet the requirements of the MIPS track. Groups subject to MIPS rules will have the opportunity to earn up to an extra 4 percent (or lose up to 4 percent) on its reimbursement rates in 2019 (based on 2017 performance). The carrots and sticks metrics ramp up to a potential 9 percent gain or loss by 2022.
Take Advantage of Increased Flexibility
The beauty of MIPS is that it offers increased clinician flexibility by allowing providers to choose measures and activities appropriate to the type of care you provide. This is an important improvement over the programs MACRA replaces.
Here is a breakdown of the reporting requirements for 2017 in the proposed rule, which likely also will be reflected in the final rule:
Quality Score: 50%
This requirement replaces the PQRS and the quality component of the Value-Based Payment Modifier. Clinicians would choose six metrics (down from nine in the PQRS) that best convey practice quality and include a variety of options tailored to different specialties and physician group types.
Advancing Care Information: 25%
This requirement effectively replaces MU and allows clinicians to select customized metrics that best reflect your day-to-day use of EHRs, instead of the “all or nothing” approach of MU. There would be an emphasis on interoperability and information exchange, and quarterly reporting would be eliminated.
Clinical Practice Improvement Activities: 15%
Clinicians would be rewarded for activities focused on care coordination, beneficiary engagement and patient safety. Clinicians may select activities that match goals they have set in their practices, from a vast list of 90 options. Here, practices could also receive credit for any participation in APMs or patient-centered medical homes (PCMH).
Costs: 10%
This replaces the cost component of the Value-Based Payment Modifier, also called Resource Use. Clinicians would have no reporting requirement for this portion of the MIPS score, which would be based on Medicare claims. However, practices will want to closely monitor cost trends to best compete on this measure.
Make Sure Your EHR System is Ready for MACRA, Too
Practices using a robust EHR that is supported by a vendor with a strong track record of compliance with government initiatives should not fear MACRA/MIPS. In fact, you should be receiving ongoing guidance from your vendor about any required updates.
It’s important that your EHR/PM is “MIPS-ready” and has the functionality required to address the component parts of the MACRA law and final rule, including MU, PQRS and the Value-Based Payment Modifier program. For practices that still haven’t implemented an EHR, MIPS provides a strong financial incentive to make the digital leap.
EHR vendors should be able to help users accumulate all of the metrics that will comprise a practice’s customized quality score, and help them seamlessly record their “advancing care” activities. MIPS-ready EHRs should reflect clinical practice improvement activities and help practices monitor and control utilization and costs.
While these new regulations will certainly demand a change in workflow and operations, technologies that are already MACRA- and MIPS-ready can help smooth the transition and ease administrative burdens. If implemented successfully, this approach can boost—rather than harm—your practice’s bottom line.