CMS Pay for Physician Performance Effective January 1, 2017
On October 14, 2016, CMS released the final rule implementing the Medicare Access and CHIP Reauthorization Act, commonly known as MACRA. The final rule spans nearly 2,400 pages, and will be open for comment for 60 days with the potential for more changes. The most significant impact is the flexibility provided by CMS during a one-year transition period.
MACRA, in short, replaces the Medicare Sustainable Grown Rate formula, and implements a Quality Payment Program designed to promote value-based care and shift physicians away from fee-for-service reimbursement. To achieve incentives or avoid penalties under MACRA, physicians will participate in one of two reimbursement tracks:
(1) The merit-based incentive payment system (MIPS), which sunsets and consolidates components of three existing programs, the Physician Quality Reporting System (PQRS), the Physician Value-based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program, and adds a fourth Clinical Practice Improvement Activities reporting category.
(2) Advanced alternative payment models (APMs), such as the Comprehensive ESRD Care Model, Comprehensive Primary Care Plus Model, Medicare Shared Savings Program Tracks 2 and 3, or Next Generation ACO Model.
In the final rule, CMS refers to 2017 as the “transition year,” and states physicians new to Medicare in 2017 as well as clinicians who bill Medicare Part B for less than $30,000 a year or provide care for less than 100 Medicare patients are initially exempt. CMS also increased flexibility in participation for other providers, and will implement a “pick your pace” structure in 2017. For example, clinicians may choose to report a minimum amount of data for at least a 90-day period to potentially qualify for a positive payment adjustment. Alternatively, clinicians may choose not to report any activity in 2017, yet will receive the full negative payment adjustment as a result.
Data collected throughout the first performance year will determine payment adjustments beginning January 1, 2019. Payment adjustments under MIPS start at 4% and gradually increase to 9% in 2022. Eligible physicians may alternatively choose to participate in advanced APMs to comply with MACRA (and thus avoid MIPS). Participants may receive 5% lump sum incentive payments beginning in 2019 under advanced APMs. CMS also indicated plans to increase opportunity for participation in advanced APMs in 2017 and 2018.
Among myriad other health care services, Murer Consultants, Inc. specializes in federal regulatory compliance including Medicare reimbursement. Given the variety of complex options now available to clinicians, Murer is available to assist in analyzing the best route for initial participation in MACRA.
Murer will also continue to monitor the development of MACRA implementation and provide updates. Please contact us at (708) 478-7030 for more information regarding Murer’s regulatory compliance and other health care services.