Don?t just get your MACRA done, get your MACRA won

Thursday, February 23, 2017 | Larry Sobal

I’ve enjoyed the recent H&R Block commercials featuring actor Jon Hamm, best known for his portrayal of iconic ad man Don Draper in AMC’s hit television series Mad Men. I thought the ads’ message, “Don’t just get your taxes done, get your taxes won,” was a good segue to talk about MACRA this week.

The Medicare Access and CHIP Reauthorization Act, known as MACRA, is a 2,398-page set of regulations introducing changes in how physicians will deliver health care and how they will be paid by CMS. Since 2015, when Congress passed this significant Medicare payment reform legislation, physicians have treated the measure as something to deal with sometime in the future. That future arrived on January 1st.

For anyone who thinks the new President, Congress, and HHS Secretary are going to eliminate MACRA, it does not appear likely given its original bipartisan support. Plus, the American Medical Association, the American Hospital Association, and over 100 other health care entities have appealed to the Administration to preserve it. You can read their January 25th letter here.

Although CMS released the final rule for MACRA in October, there is still quite a bit of confusion about it. In fact, per Deloitte’s survey of 600 doctors in 2016, nearly half of U.S. physicians indicated they were not even familiar with MACRA.

I’m here to tell you that MACRA doesn’t have to be scary, confusing or even difficult to succeed in. In fact, I am consistently telling practices that MACRA is a great opportunity to improve their reimbursement. Below is a summary of what you need to know now.

1. MACRA gives physicians two options for participating in the Quality Payment Program (QPP). One is the Merit-based Incentive Payment System (MIPS), the other is to qualify as an advanced alternative payment model (APM), such as an accountable care organization. Unless you are one of just a small number of organizations in a qualifying APM, all you need to focus on is MIPS.
2. CMS was actually trying to do physician practices a favor and chose to make 2017 a transition year with four choices for how to participate in MACRA this year:

a) Non participation will mean a negative payment adjustment. If 2017 data is not submitted by March 2018, non-participants receive a negative 4% payment adjustment.

b) Minimal (testing) participation in CY 2017 requires reporting on at least one Quality measure, or one Improvement Activity, or the required measures in the Advancing Care Information (ACI) category on a single Medicare Part B patient for any period of time in CY 2017. It avoids a negative Part B payment reduction in CY 2019 and likely earns no positive payment adjustment.

c) Partial participation in CY 2017 requires reporting on more than one Quality measure or more than one Improvement Activity or reporting more than the required measures in the ACI category for a continuous 90-day period sometime between January 1 and December 31. It avoids negative Part B payment adjustment in CY 2019 and could earn a small upward Part B payment adjustment. An eligible clinician must begin measurement reporting no later than October 2, 2017 to satisfy the continuous 90-day period requirement.

d) Full participation in CY 2017 requires reporting for at least a continuous 90-day period or, ideally, the full year on the required number of measures in each of the six Quality measures (including one outcome measure or one specialty-specific or subspecialty-specific measure set), Improvement Activity (up to four activities), and ACI (five required measures) categories. It avoids negative Part B payment adjustments in CY 2019, could earn positive payment adjustments, and may result in an exceptional performance bonus for eligible clinicians with performance scores of 70 or above.

That brings me back to how to get your MACRA won. To start with, I can’t see any reason why a practice would choose option a) and not participate. Winning in MACRA means you need to at least go with option b) and take steps to avoid negative payment adjustments 2019. CMS reduced the MACRA requirements so much that to avoid the automatic penalty, you have to do almost nothing in 2017. Option b) only requires you to report at least one Quality measure and one Improvement Activity or a minimum of five required ACI measures; that should be an automatic for virtually all practices.

The winning choice is option c), or better yet, option d) to maximize your reimbursement and bonus potential, especially since the possible benefits and penalties grow in coming years and practices should do as much as they can this year to be better prepared for 2018’s stiffer requirements.

MACRA doesn’t have to be scary, confusing or even difficult to succeed in.

 

Choosing option d) has two benefits. First, it puts you in position for positive reimbursement changes in 2019. Second, you will be in the best position for success beyond 2019 because you will not know if you’ve made errors in collecting and reporting 2017 data until you receive your 2019 payments, and then it’s too late to fix any mistakes. You would then be another two years away from receiving positive impact.

If you choose full participation in MACRA in 2017, you give yourself the best opportunities to earn a 4% payment increase in 2019 (potentially growing to 9% in 2022) and a portion of an “exceptional performance” bonus pool of $500 million that has been set aside for eligible clinicians who receive a MIPS reporting score of 70 or more in CY 2017. The bonus will be at least 0.5% and no more than 1.0%. Exceptional performance bonuses are now slated to be available in each of the Quality Payment Program’s first six years. Earning these incentives can mean a significant financial boost to your practice.

Want more information on how to get your MACRA won? Below are some resources including the CV Transforum Spring’17 conference that will have a MACRA pre-con deep dive as well as other MACRA presentations.

• A recent article on Maximizing Reimbursement Through MACRA MIPS
• MedAxiom’s MACRA Resource Center
• CMS’ Quality Payment Program Web Site
• CV Transforum Spring’17 Conference with MACRA Pre-Con Session Agenda

 

Illustration: Lee Sauer

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Larry Sobal is Executive Vice President and a Senior Consultant at MedAxiom. He has a 35-year background as a senior executive in medical group leadership, hospital leadership and health insurance. Larry consults, writes and presents on topics relevant to transforming physician practices and health systems. His weekly blog post comes out on Thursdays and can be accessed at www.medaxiom.com.

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