MACRA: CMS issues final rule

11/4/2016

Top 10 things to know

RMedowsMACRASince March, we have been strategizing and educating our organization to prepare for MACRA, and just this month on Oct. 14, CMS issued the long-awaited final rule. Between now and the end of this year, everyone in our industry will be learning how the requirements of Medicare’s news Quality Payment Program under MACRA will affect them. 


Here are 10 things for you to know about the final rule:

  1. When will MACRA take effect?
    The performance year has not changed and MACRA will take effect on Jan. 1, 2017. 

  2. Who qualifies for the Quality Payment Program?
    Providers: physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists. 

  3. Will we have flexibility in our level of participation during the first year?
    Yes. The final rule allows clinicians to “pick their pace” of participation to avoid payment penalties. However, regardless of what we choose, we’ll have to be prepared to report by March 31, 2018 on our 2017 performance.

  4. Are there still four payment categories for performance year 2017?
    No. The “Cost/Resource Use” Category was eliminated for 2017. Now, there will be more focus on the Quality category. Clinicians will be measured only on their reported performance in: Quality (60%); Clinical Improvement (15%); Advancing Care Information, formerly Meaningful Use (25%) and Cost Category (0%). 

  5. Will there be an opportunity for virtual reporting among groups?
    Through our advocacy and conversations with CMS, we learned the agency did not have the infrastructure in place to respond to our request and allow groups to “split” tax identification numbers (TINs) if they choose to participate in MIPS as a group. CMS may address this in future years of the program and we will continue to advocate and work with CMS to add this flexibility for group reporting. 

  6. Do small, rural practices still have to participate the first year?
    Clinicians billing $30,000 or less of Medicare charges, or that see 100 or fewer Medicare patients will not be required to participate in the MIPS. 

  7. Did Merit-based Incentive Payment System change in the final rule?
    The number of MIPS performance metrics has not changed. However, the number of reported metrics required under two of these categories—Advancing Care Information and Clinical Practice Improvement Activities—has been reduced to five and four, from 11 and six, respectively.

  8. What qualifies as an advanced Alternative Payment Model?
    Although not fully outlined in the final rule, CMS indicated possible future amendments to existing programs and the development of new programs that would create additional stepping stones for providers to take on risk. This would make the path toward the Advanced APM track more gradual. 

  9. Where can I learn more?
    The very helpful Regulatory Alert from our Government Affairs team includes a detailed summary of the final rule and our advocacy work. I encourage you to read it, and there you will find links to additional resources. Below, you will also find a link to my MACRA presentation at the 2016 Healthy Communities Summit, which was just before the final rule came out and is still applicable for you to view. 

  10. What are our next steps?
    Government affairs and population health will be working in partnership to submit comments on specific aspects of the final rule. In addition, we will continue our MACRA Strategy Committee work and quickly evaluate next steps.