From the Consultant’s Corner 4/6/17
Getting the Lay of the MACRA Land This Year and Next
Despite the change in administration, MACRA, with its Quality Payment Program, is here for at least awhile, having received tremendous bipartisan support in Congress. Because there is significant upside and downside Medicare payment risk, it is essential for all providers to prepare for this new QPP.
Who Participates
If your organization is actively participating in advanced Alternative Payment Models, then the participation in this QPP is covered. However, only 10 percent of providers fall into this category. If there are few Medicare charges or patients, or a new Medicare provider, you do not have to participate. Therefore, most physicians and practice groups will fall under the category of participating under the Merit-based Incentive Payment System program.
Core Components
While MACRA is very similar to the PQRS, Value Modifier, and Meaningful Use programs, it attempts to align all three programs via four components:
- Quality (numerous metrics to choose from)
- Resource Utilization (cost will not be a factor in 2017 and only 10 percent in 2018)
- Advancing Care Information (use of an EHR, with numerous metrics to choose from)
- Clinical Practice Improvement Activities (process improvement – demonstrate core capabilities plus a few additional metrics to choose from)
Performance in these categories is weighted and begins with 60-percent quality, 25-percent advancing care information, and 15-percent process improvement. In two years the weighting will change to 30-percent quality, and 30-percent resource utilization, while advancing care information and process improvement will stay the same at 25 percent and 15 percent, respectively.
Just as with PQRS, there are still multiple ways to report. You can report as an individual provider with an NPI/TIN or as a group of physicians under one TIN. Reporting can take place via claims, registry, CMS website, Qualified Clinical Data Registry or through the EHR system.
There is a significant upside and downside to starting at 4 percent of fee scheduling and ending up at 9 percent over the next four years. This will be based, in large part, on balance budget. Therefore, there will be winners and losers, and providers will essentially be competing against one another. Above all, there is a $500 million pool of money to be shared by the exceptional performers.
What is Important for 2017?
In recognition of the complexity of a new program, many individuals and practices that have not previously reported will begin reporting. CMS has decided that the threshold to avoid a negative penalty should be very low for 2017. As long as one metric – a quality metric, performance improvement project attestation, or the minimum standard of EHR use – is met, the provider/group will not be penalized for their 2017 performance. Because very few will be penalized, there will also be little upside gain. Providers can use 2017 as a year to develop overarching strategy and infrastructure, rather than worry about whole-scale reporting.
Strategy
Typically, many practices put their finance and IT departments in charge of selecting measures that are feasible to report on, reporting, and ensuring accuracy. However, this is a good time for organizations to step back and take a broader look at their organization, which typically includes:
- CIO – Meaningful Use
- CFO – PQRS
- CMO – Quality
- Population Health Lead
- CMIO – EHR Deployment and Optimization
This program provides an opportunity to pull together these leaders and consider organizational strategies. It allows the leadership to then pick metrics and projects that will support their long-term vision, and focus resources on those areas that will most likely help the broader quality goals of the organization. This would create sustainable improvement and optimize performance.
This year is a great one to select a few metrics that are easy to perform to get one’s feet wet and develop a strategy and infrastructure to support MACRA and QPP for the long run.
Nancy Gagliano, MD is CMO at Culbert Healthcare Solutions in Woburn, MA.
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