This past summer, over 300 stakeholders voiced their concerns and beliefs to the Centers for Medicare and Medicaid Services (CMS) about the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA. As part of the ramp-up to the 2017 implementation, continuing medical education providers have been preparing courses to help healthcare providers understand how to implement MACRA and its quality improvement principles for their practices—something many told CMS they believe is essential.
In a blog post, CMS announced changes to MACRA that will allow physician practices 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 pressure from industry stakeholders and policymakers to ease implementation of MACRA, which is set to start January 1, 2017. It has been reported that CMS has been considering a potential MACRA delay, and this appears to be what the agency will decide in its final rule November 2016.
The Announcement
Acting CMS Administrator Andy Slavitt announced that the final MACRA regulation will exempt physicians from any risk of penalties if they choose one of three distinct Merit-Based Incentive Payment System (MIPS) reporting options in 2017, in addition to the option of participating in an advanced Alternative Payment Model, or APM:
- Full-year reporting that begins on January 1;
- Partial year reporting for a reduced number of days; or
- A "test" option under which physicians can report minimal amounts of data.
Physicians who report in 2017 may be eligible for bonus payments in 2019, depending on which option they choose. Those who opt for full-year reporting will be eligible to receive a "modest positive payment adjustment"; those who choose partial-year reporting will be eligible for a "small positive payment adjustment." Physicians who choose the "test" option will not be subject to any payment adjustments. Qualified participants in advanced APMs will be eligible for 5 percent incentive payments in 2019.
The Reaction
Response to the announcement was largely positive. Many groups submitted comments to CMS for the proposed MACRA rule calling upon the agency to delay the start of MACRA or to offer flexibility, especially for smaller and solo practices. This comes as a new report indicates that many physicians are worried about MACRA's new practice burdens. In general, most physicians still do not understand MACRA, even though the first performance period starts in 2017.
Delay Provides Opportunity to Learn
In the initial analysis of the MACRA proposed by CMS, small practices with 10 or fewer physicians were expected to face penalties.
There a huge need to help healthcare providers, especially small practices, understand how to implement MACRA when the final rule is announced. In the meantime, though, all of MACRA is predicated on implementing quality improvement in practices. This temporary delay provides the opportunity to work with those practices to ensure that they succeed under a system that is complex, but not insurmountable.
Medical practices—and the care they provide to patients—improve as they learn the principles of quality improvement and how to practically implement those principles and measures. As educators prepare for courses in 2017, it gives us an opportunity to consider how we can further include topics on implementing quality measures in our courses.
It is encouraging to see conferences such as MEDX springing up around the country to help practices understand how to implement these complex policies and benefit patients at the same time.
If it all works, 2017 will not just be the year we implement MACRA, but also the year quality improvement will become front and center in patient care.
