Things to know right now about MACRA

Cate Brandon

More than 2 years since then-President Barack Obama signed the Medicare Access and CHIP Reauthorization Act — or MACRA — into law, many medical professionals appear to need assistance on applying the 2015 law to their practices.

Recently, ACP and AMA separately sent letters to CMS asking that agency to improve certain components of the legislation, while an AMA survey released earlier this summer indicated that more than 50% of all doctors are not ready for MACRA.

Cate Brandon, JD, an associate at Arnold & Porter Kaye Scholer, said in an interview that there is a need for MACRA, but that doesn’t make carrying it out any less daunting.

“The [previous] system with separate programs was not working. The idea of MACRA to streamline those requirements makes sense. The drive for paying for quality and outcomes as opposed to fee for service makes sense in a lot of situations,” she told Healio Family Medicine in an interview. “But it is challenging to implement something like that.”

To help physicians better understand MACRA, Healio Family Medicine asked Brandon for some additional tips that medical professionals need to know right now about MACRA:

Determine if MIPS applies

The first thing medical professionals should do, she said, is determine if they are subject to Merit-Based Incentive Payment System, or MIPS. A letter was sent out to physicians at the Tax Identification Number level earlier this year that explained the following health care professionals need to submit data in 2017 in order to avoid a negative payment adjustment in 2019: doctors of medicine, osteopathy (including osteopathic practitioners), podiatric medicine, optometry, dental surgery, dental medicine, and chiropractors; physician assistants; nurse practitioners; clinical nurse specialists; certified registered nurse anesthetists; and group(s) including such clinicians. However, clinicians from the provider types above that do not bill $30,000 or more in Medicare Part B allowed charges a year and provide care to more than 100 Part B-enrolled Medicare beneficiaries a year are not required to participate in MIPS.

It’s not too late

“It’s not too late to start participating to avoid a negative payment adjustment or even get a positive payment adjustment,” Brandon said. “The requirement in 2017 is that you only need to collect data for 90 consecutive days, which means you could start as late as October 2 of this year, and still be able to report the minimum number of days... The deadline for reporting [this data] is March 31, 2018.”

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Pick your pace

“CMS is being very incremental in its approach this year. In order to avoid a negative payment adjustment, there’s a minimal amount of reporting that needs to be done. An eligible physician can report just one quality measure, just one improvement activity or the requirements for the base score for the advancing care information category, which is the EHR category,” Brandon said.

CMS’s website lists more than 250 quality measures — including adult sinusitis, one-time screening for hepatitis C virus for patients at risk and use of high risk-medications in elderly patients — from which medical professionals can choose to report on.

In addition, the agency has stated that the more than 90 improvement activities fall into one of the following subcategories: achieving health equity, behavioral and mental health, beneficiary engagement, care coordination, emergency response and preparedness, expanded practice access, patient safety and practice assessment, and population management.

Base score measures for advancing care information are based the edition of certified electronic health record technology used. For those medical professionals utilizing a 2014 certified edition of this technology, base score measures are e-prescribing, health information exchange, provide patient access, security risk analysis. For those using the 2015 certified edition, base measures are e-prescribing, request/accept summary of care security risk analysis, provide patient access, and send a summary of care, according to CMS.

“Submitting any one of these three things will satisfy the minimum number of points needed to avoid the negative payment adjustment...” Brandon said. “The more data you submit, the more likely you are to get a positive payment adjustment.”

Limited changes planned for 2018

“[Under 2018 proposals], most of the requirements will remain the same as in 2017. CMS is also proposing in 2018 to keep the cost category at 0% of [the composite performance score] determining payment adjustments,” she said. “They’re also proposing streamlining and easing reporting burdens, increasing the number of clinicians that may not need to participate in MIPS because they may not meet the low volume threshold.” A final decision on these proposals will come this fall.

The AAFP, AMA, and ACP also have materials that medical professionals can use to better understand MACRA.

Starting in 2019, MACRA creates two physician payment options: the merit-based incentive payment system that consolidates the current incentive programs; and eligible alternative payment models, such as certain accountable care organizations and bundled payment models. – by Janel Miller

Additional resources:

•MACRA: The Medicare Access and CHIP Reauthorization Act. http://www.aafp.org/news/macra-ready.html Accessed Sept. 6, 2017.

•Frequently Asked Questions: Medicare Access and CHIP Reauthorization Act of 2015.

http://www.aafp.org/practice-management/payment/medicare-payment/faq.html Accessed Aug. 29, 2017.

•CMS Quality Payment Program Webpage. https://qpp.cms.gov/ Accessed Aug. 29, 2017.

•CMS Frequently Asked Questions. https://questions.cms.gov/ Accessed Aug. 29, 2017.

•MACRA and the Quality Payment Program.

https://www.acponline.org/practice-resources/business-resources/payment/medicare/macra Accessed Aug. 29, 2017.

•Quality Payment Program (QPP) Specifics. https://www.ama-assn.org/practice-management/quality-payment-program-qpp-specifics Accessed Aug. 29, 2017.

Disclosure: Brandon reports no relevant financial disclosures.