CMS Offers Four Options on MACRA Requirements
Written by Editor   
Tuesday, September 27, 2016 12:00 AM

The CMS announced it will allow providers to choose the level and pace at which they comply with the new payment reform model aimed at emphasizing quality patient care over volume.  The announcement comes after intense pressure from industry stakeholders and policymakers to ease implementation of the Medicare Access and CHIP Reauthorization Act, which is set to start Jan. 1, 2017. Two months ago, CMS Acting Administrator Andy Slavitt said the agency was considering delaying the start date.  

“In recognition of the wide diversity of physician practices, we intend for the Quality Payment Program to allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017," CMS acting administrator Andy Slavitt wrote. "During 2017, eligible physicians and other clinicians will have multiple options for participation. Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019."

Under the Medicare Access and CHIP Reauthorization Act (MACRA) — the bill that repealed the sustainable growth rate formula for physician reimbursement under Medicare -- physicians must choose from one of two paths beginning next year: they can either participate in an alternative payment model such as an accountable care organization, or they can join in the Merit-Based Incentive Payment System (MIPS), which requires doctors to submit quality reporting data to Medicare.  Next year, eligible physicians and other clinicians will be given four options to comply with new payment schemes such as the Merit-based Incentive Payment System (MIPS) or an alternative payment model such as accountable care organizations.  Under MIPS, physician payments will be based on a compilation of quality measures and the use of electronic health records. About 90% of physicians are expected to pursue MIPS because a qualifying APM requires a hefty amount of risk. 

Slavitt outlined four options for physicians:

  • Test the Quality Payment Program. "With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment," he wrote. "This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more."

  • Participate for part of the calendar year. Under this option, physicians could submit quality information "for a reduced number of days," Slavitt explained. "This means your first performance period could begin later than January 1, 2017 and your practice could still qualify for a small positive payment adjustment. ... You could select from the list of quality measures and improvement activities available under the Quality Payment Program."

  • Participate for the full calendar year. Practices that are ready to start on Jan. 1 could submit quality information for a full year, and thus could qualify for a "modest" payment adjustment, he said. "We've seen physician practices of all sizes successfully submit a full year's quality data, and expect many will be ready to do so."

  • Participate in an Advanced Alternative Payment Model in 2017. Practices that choose not to report quality data could instead join an advanced alternative payment model, such as a Medicare Shared Savings program, in 2017. "If you receive enough of your Medicare payments or see enough of your Medicare patients through the advanced alternative payment model in 2017, then you would qualify for a 5% incentive payment in 2019," Slavitt noted.

More details on these options will become available when CMS releases its final rule for implementing the Quality Payment Program, sometime before Nov. 1, Slavitt noted. “We appreciate the sincere and constructive participation in the feedback process to date and look forward to advancing step by step in that same spirit."  Lawmakers had shown great concern for small and rural practices, which have said MACRA could force them to join hospitals or larger practices because of the paperwork and payment changes required.