Preparing for MACRA

Education – webinars, videos available on the CMS website:

Who Qualifies: You are eligible to participate in the MIPS track of the Quality Payment Program if you bill more than $30,000 to Medicare Part B, and provide care to more than 100 Medicare patients per year and you are a:

Physician – Physician Assistant – Nurse Practitioner – Clinical Nurse Specialist – Certified Registered Nurse Anesthetist

If you are eligible and choose to not participate in the program, you will receive the maximum amount of penalty!

If your first year participating in Medicare is 2017 – then you are not required to participate in the Quality Payment Program in 2017.

If you are ready – you can begin January 1, 2017 and start collecting data. If not ready – you can start anytime between January 1 and October 2, 2017. Performance data is due March 31, 2018. First payment adjustments go into effect January 1, 2019.

Your Merit-Based Incentive Payment System (MIPS) Options:

  1. Submit at least some data (Pick Your Pace) to CMS’s new Quality Payment Program in 2017 – no financial penalty
  2. Start submitting the full range of data required by CMS anytime in 2017 – qualify for partial payment (if you do well)
  3. Submit data for the full calendar year and qualify for full bonuses, again assuming you do better than average on the measures (QRUR Reports)
  4. Your Alternative Payment Models Option

  5. Become a member of one of MACRA’s Alternative Payment Models (APMs) – include certain accountable care organizations (ACOs) and the 5,000 practices that will participate in CMS’ new Comprehensive Primary Care Plus demonstration – this option involves financial risk to the practice – automatically receive 5% annual bonuses for 5 years starting in 2019

Practices should consult with their EHR vendors to find out when their products will be ready for MIPS. Current 2014 Certified versions of EHRs will be allowed by CMS until 2018 – then switch or update to EHRs that meet different certification standards.

Since CMS has allowed greater flexibility, practices can wait until they receive upgrades to their system before beginning to report in 2017 – this allows them time to switch EHRs to meet requirements (THE DEADLINE FOR BEGINNING PROGRAM IS OCTOBER 2, 2017).

Practices that have submitted PQRS in the past can access their Quality and Resource Use Reports (QRURs) to see where they stand on quality measures compared to their colleagues since 60% of their scoring will be the Quality category. Some cloud-based EHRs provide benchmarking services and if previous submissions were through qualified clinical data registries you can check your measures there.

There are three (3) categories for comparative performance - Quality – 60%; Advancing Care Information (ACI) – 25%; Improvement Activities (CPIA) – 15% - the Resource (Cost) category was removed for calculating performance for 2017

Quality – 60%

  • Individuals - 6 measures out of 271 or 1 of 30 specialty measure sets, including an outcome measure for a minimum of 90 days
  • Groups – report 15 quality measures for a full year if using a web interface
  • Groups in APMs – for special scoring under MIPS, such as Shared Savings Program Track 1 or the Oncology care Model – report quality measures through your APM. No need to do any additional for MIPS quality

Advancing Care Information – 25%

  • Replaces the Medicare EHR Incentive Program (aka Meaningful Use)
  • Fulfill the required measures for a minimum of 90 days
    • Security Risk Analysis
    • e-Prescribing
    • Provide Patient Access
    • Send Summary of Care
    • Request/Accept Summary of Care
  • Choose to submit up to 9 measures for a minimum of 90 days for additional credit.
  • Bonus credit – report Public Health and Clinical Data Registry Reporting measures – use certified EHR technology to complete certain improvement activities in the improvement activities performance category OR you may not need to submit advancing care information if these measures do not apply to you.

Improvement Activities – 15%

  • Individuals – attest that you completed up to 4 improvement activities out of 90 for a minimum of 90 days
  • Groups with fewer than 15 participants or if in a rural health professional shortage area (HPSA) – attest that you completed up to 2 activities for a minimum of 90 days
  • Participants in Patient-Centered Medical Home, comparable specialty practices, or an APM designated as a Medical Home Model – you will automatically earn full credit
  • Participants in certain APMs under the APM scoring standard, such as Shared Savings Program Track 1 or Oncology Care Model – you will automatically receive points based on the requirements of participating in the APM. For all current APMs under the APM scoring standard, this assigned score will be full credit. For all future APMs under the APM scoring standard, the assigned score will be at least half credit.

For practices who have been participating in the government’s incentive programs to date, you will likely have an easy transition to this new program.

The key is to start preparing now!