MACRAlerts

MACRAlert

October 14, 2016

Statement from the American College of Rheumatology Regarding CMS Final Rule on MIPS and APMs

While we have not had time to review the final rule in its entirety, we are encouraged to see that the Centers for Medicare and Medicaid Services (CMS) is listening to the concerns raised by the American College of Rheumatology (ACR) regarding the need for reporting requirements that are simple, transparent, and tenable – especially for small and rural rheumatology practices. Giving providers the flexibility of multiple options for participation in the first and second years will help ensure a smooth transition to the new payment system, and the continued delivery of quality care to Medicare patients living with rheumatic diseases. We also appreciated the broadening of exemptions from the program, which will help to protect small practices that already struggle to keep up with administrative burdens, along with the reduction in the number of required measures to be reported.

We were also pleased to see that qualified clinical data registries (QCDRs) – including ACR’s Rheumatology Informatics System for Effectiveness (RISE) registry – were included as a reporting mechanism that MIPS-eligible clinicians and groups can use as intermediaries to submit data on measures and activities, decreasing the burden to individual rheumatologists. Utilizing QCDRs to streamline and integrate quality reporting programs will give providers more flexibility and help realize the shared goal of improving patient outcomes under MACRA.

The ACR’s policy and legislative staff are closely examining the rule to determine whether some of the other key concerns raised by the rheumatology community – such as the inherent problems with the Resource Use category of MIPS, and the formidable barriers that exclude many rheumatologists from participating in the Alternative Payment Model (APM) track – have been sufficiently addressed.

MACRA Details

Final Rule
Executive Summary
Quality Payment Program Website

September 9, 2016 Alert

The Centers for Medicare & Medicaid Services (CMS) announced yesterday that it will give providers several options to comply with the new quality payment program being implemented under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

The announcement signals that the agency is listening to the concerns voiced by the American College of Rheumatology and other healthcare providers, and comes on the heels of House and industry leaders asking the Department of Health and Human Services for more flexibility with MACRA implementation. This article highlights the lawmakers’ letter and the ACR’s comments to CMS requesting flexibility.

Background
MACRA ended the Sustainable Growth Rate (SGR) formula that determined yearly payment adjustments to providers under Medicare and replaced it with a two-part system that links quality to provider payments.

  • The Merit-Based Incentive Payment System (MIPS) combines several programs used to measure care quality into four tiers focused around: quality, resource use, clinical practice improvement, and use of electronic health record technology.
  • The Alternative Payment Models (APMs) established new ways for Medicare to pay healthcare providers through mechanisms such as lump-sum incentive payments, bundled payments, Accountable Care Organizations, and Patent Centered Medical Homes.

New Options Announced for Providers
For the first year of MACRA’s implementation, providers will have several options to choose from to avoid facing a negative payment adjustment. “During 2017, eligible physicians and other clinicians will have multiple options for participation. Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019. These options and other supporting details will be described fully in the final rule,” said Acting Administrator Andy Slavitt in this CMS blog post.

The four options available to providers are:

  • Test the quality payment program: With this option, as long as providers submit some data to the quality payment program, including data from after January 1, 2017, they will avoid a negative payment adjustment. This first option is designed to ensure that provider systems are working and that they are prepared for broader participation in 2018 and 2019. Participants who choose this option would not be subject to any payment adjustment.
  • Participate for part of the calendar year: Providers may choose to submit quality payment program information for a reduced number of days. This means their first performance period could begin later than January 1, 2017, and their practice could still qualify for a small positive payment adjustment. For example, if they submit information for part of the calendar year for quality measures, how their practice uses technology and what improvement activities their practice is undertaking, they could qualify for a small positive payment adjustment. Providers could select from the list of quality measures and improvement activities available under the quality payment program. Participants who choose this option would receive a “small positive payment adjustment.”
  • Participate for the full calendar year: Practices that are ready to go on January 1, 2017, may choose to submit quality payment program information for a full calendar year. This means their first performance period would begin on January 1, 2017. For example, if they submit information for the entire year on quality measures, how their practice uses technology and what improvement activities their practice is undertaking, they could qualify for a “modest positive payment adjustment.”
  • Participate in an advanced alternative payment model in 2017: Instead of reporting quality data and other information, the law allows providers to participate in the quality payment program by joining an advanced alternative payment model, such as Medicare Shared Savings Track 2 or 3 in 2017. If providers receive enough of their Medicare payments or see enough of their Medicare patients through the advanced alternative payment model in 2017, then they would qualify for a 5% incentive payment in 2019.

The ACR thanks CMS Acting Administrator Slavitt and HHS Secretary Burwell for listening to physicians and providing the flexibility needed for a successful launch of the new MACRA payment systems. The ACR will continue to provide guidance for its members as it analyzes options and discusses plans with CMS leaders.

 

Register for RISE

As rheumatologists prepare for MACRA, we encourage ACR members to sign up for and utilize the Rheumatology Informatics System for Effectiveness (RISE) Registry, a database developed and managed by the ACR. RISE is free to ACR members and has been designated a qualified clinical data registry (QCDR), meaning that rheumatology providers who wish to use RISE for MIPS reporting can do so automatically. Participation in RISE will be key to rheumatologists’ success in the MACRA era of payment reform. Learn more about RISE >