It’s the moment that Medicare Part B clinicians and healthcare administrators have been waiting for. The final release of the MACRA Quality Payment Program! Health & Human Services released the rule amidst much publicity, a response to thousands of comments and industry feedback throughout the year.
I would summarize the theme of the final ruling as, “Empowering physicians to achieve the Triple Aim through choice and health IT”. My colleague Dr. Brad Miller, who contributed to the ideas in this post, also said it well in this recent blog post: “CMS’ ultimate goal with MACRA is to move healthcare further to a system based on quality, and to accelerate the shift in how providers use technology to improve patient care and outcomes.” Here are some of our key takeaways on the final release:
- Per the earlier “Pick your Pace” communique from acting CMS administrator Andy Slavitt, clinicians can still choose one of three participation pathways for Performance Year 2017:
– Submit minimum data by March 2018 to avoid a negative payment adjustment
– Submit partial data to earn neutral or minimal positive payment adjustment
– Submit complete data to earn a moderate payment adjustment
- Clinicians will not be scored on the Resource Use category until 2018. In the absence of Resource Use, the Quality category raises to 60% of the MIPS composite score for PY2017.
– Overall, while choosing which quality measures to choose will remain a challenge, by pushing out the Resource Use category until 2018, CMS is giving providers more time to analyze their data and intelligence to drive the necessary practice changes for improved Resource Use performance. Identifying these areas for RU and enacting change represents a significant practice and workflow re-design effort for providers and this extra year represents a more realistic timeframe under which providers can adapt.
- Clinical Practice Improvement Activities have been renamed to the simpler, “Improvement Activities” category.
- CMS has provided much clearer guidance on how existing alternative payment models (APMs) will qualify for different categories:
– As previously assumed, CMS established the quality reporting requirements for Medicare Shared Savings Plan (MSSP) Track 1 as sufficient for the Quality category.
– Medical Homes, and advanced APMs, will earn full credit for the Improvement Activities category; MSSP Track 1 and Oncology Care will receive points based solely on their APM participation.
- Advancing Care Information requirements differ based on EHR edition:
– Patient-generated health data is an opportunity for those reporting prior to the 2017 edition to start learning from the copious amount of wearable and patient-reported data now in the marketplace.
- CMS has supplied the healthcare public with fantastic, easy-to-use resources on the new CMS Quality Payment Program (QPP) site. Users can select and export their a la carte activities or measures for easy tracking.
Taken together, these changes reflect the ability of healthcare organizations to choose how they adopt MACRA. First, providers have been given a little more breathing room to gather their understanding and strategy for MACRA overall. This helps with the widespread sentiment that providers were overwhelmed on how and what to report in the first year. Second, there is a more gradual focus of scoring on smart fiscal skills and slowed rollout of large downward payment adjustments which aims to decrease overall MACRA performance and financial anxiety. Finally, CMS motivates providers to get ahead of the rule by supplying incentive bonuses for underrepresented types of quality measures or for demonstrating advanced registry usage.
2017 represents a time for providers to get educated on MACRA’s subtleties, gather needed data and intelligence and develop go-forward strategies to effectively evolve with MARCA. This includes the hefty task of experimenting and training their practitioners, support staff and their tools like software solutions needed to succeed in future years. This means organizations now have an opportunity to get ahead of the requirements by creating a MACRA strategy in the remaining 2016 and beginning of 2017 to establish a flexible foundation for MACRA success. More directly and simply, CMS has listened to providers and given them more space and time to develop practice responses and strategies to adapt to this brave new MACRA world.