What does MACRA mean for you? Key takeaways
CMS’ Quality Payment Program (QPP) introduced in the Medicare Access and CHIP Reauthorization Act (MACRA) has created a seismic effect across provider organizations.
Within the QPP are two paths providers can follow: the Merit-based Incentive Payment System (MIPS) or the Advanced Alternative Payment Model (APM). The significant impact providers are feeling is due to the fact that MIPS and APM are combining three deeply entrenched CMS programs: meaningful use (MU) of electronic health records (EHRs), the Physician Quality Reporting System (PQRS) and the Value-based Modifier (VM).
In the MACRA proposed rule, the new initiatives combine elements of the existing programs, but the scoring, payment incentives and penalties are quite different. For example, under MIPS, by 2022, a provider’s negative adjustment can be 9% and positive adjustment can be up to 27%.
In addition, while the existing programs have been merged under MIPS and APM, the data capture, analysis and reporting required for compliance will be no less challenging if most of the proposed rule’s provisions are accepted when the final rule hits this fall.
Healthcare organizations that want to maximize incentive payments under the MACRA programs will need to enable the free flow of data across their enterprise so metrics can be continually analyzed to monitor and improve performance.
Quality is the emphasis
The MACRA program that most eligible clinicians will likely participate in is MIPS. MIPS evaluates performance across four categories:
Clinical practice improvement activities (CPIA)
Advancing care information (ACI)
These categories, however, are not weighted equally. The quality category represents 50% of the MIPS Composite Performance Score (CPS) in first year. Performance category weightage varies in subsequent years. Providers with strong PQRS historic performance should excel under the MIPS quality category, which is a slightly streamlined version of the expiring program. For example, MIPS quality is comprised of six measures, down from the nine measures required under PQRS, with no domain requirement, unlike PQRS. There is also at least one cross-cutting measure and an outcome measure or high-priority measure, which puts greater emphasis on outcome data capture for providers.
Additionally, bonus points will be offered for reporting higher-priority measures and using an EHR for reporting. The scores in the quality category will be assigned based on a national level percentile for the reporting clinician. This offers a radically different focus from PQRS, which emphasizes only the number of Medicare Part B patients, rather than the actual provider performance.
Under the proposed rule, quality measures will be selected annually, and the final list will be published in the Federal Register by November 1 of each year. Provider organizations can be confident that familiar Clinical Quality Measures from PQRS and VM will appear in this category.