CMS has released the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA). The rule establishes the Merit-based Incentive Payment System (MIPS) which consolidates components of the Physician-Quality Reporting System, the Physician Value-based Payment Modifier, and the Medicare EHR Incentive Program for eligible professionals.
On Wednesday, the MACRA proposed final rule was released to the public. The rule is scheduled to be published in the Federal Register on May 9. The proposal will be available for public comment for 60 days.
MACRA removes the sustainable growth rate formula, which cut Medicare payments for services, and replaced it with a .5% year-over-year increase in the physician fee schedule. The proposal links payments to value via MIPS and measures physicians in four areas: Quality, Cost, Technology use, and Practice improvement.
- Quality: For most MIPS eligible clinicians, we propose to include a minimum of six measures with at least one cross-cutting measure (for patient-facing MIPS eligible clinicians) and an outcome measure if available; if an outcome measure is not available, then the eligible clinician would report one other high priority measure (appropriate use, patient safety, efficiency, patient experience, and care coordination measures) in lieu of an outcome measure. MIPS eligible clinicians can meet this criterion by selecting measures either individually or from a specialty-specific measure set.
- Resource Use: Continuation of two measures from the VM: total per costs capita for all attributed beneficiaries and Medicare Spending per Beneficiaries (MSPB) with minor technical adjustments. In addition, episode-based measures, as applicable to the MIPS eligible clinician.
- CPIA: We generally encourage but are not requiring a minimum number of CPIAs.
- Advancing Care Information: Assessment based on advancing care information measures and objectives.
This rule proposes MIPS performance standards and a MIPS performance period of 1 calendar year (January 1 through December 31) for all measures and activities applicable to the four performance categories. The rule proposes to use 2017 as the performance period for the 2019 payment adjustment. The first performance period would start in 2017 for payments adjusted in 2019. In addition, it would allow for a full year of measurement and sufficient time to base adjustments on complete and accurate information.
As directed by the MACRA, this rule proposes measures, activities, reporting, and data submission standards across four performance categories: quality, resource use, clinical practice improvement activities (CPIAs), and meaningful use of certified EHR technology (referred to in this proposed rule as “advancing care information”). Measures and activities would vary by category and include outcome measures, performance measures, and global and population based measures. Consideration would be given to the application of measures to non-patient facing MIPS eligible clinicians.
Quality measures would be selected annually through a call for quality measures process. Selection of these measures is proposed to be based on certain criteria that align with CMS priorities, and a final list of quality measures will be published in the Federal Register by November 1 of each year. Under the standards proposed in this rule, there would be options for reporting as an individual MIPS eligible clinician or as part of a group. Some data could be submitted via relevant third party data submission entities, such as qualified clinical data registries (QCDRs), health IT vendors, qualified registries, and CMS-approved survey vendors.
The U.S. Department of Health & Human Services’ (HHS) Office of the Assistant Secretary for Planning and Evaluation (ASPE) is conducting studies and making recommendations on the issue of risk adjustment for socioeconomic status on quality measures and resource use as required by section 2(d) of the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) and expects to issue a report to Congress by October 2016. We will closely examine the recommendations issued by ASPE and incorporate them, as feasible and appropriate, in future rulemaking.
“This proposal, if finalized, would replace the current meaningful use program and reporting would begin January 1, 2017, along with the other components of the Quality Payment Program,” according to CMS acting Administrator Andy Slavitt and Karen DeSalvo, national coordinator at ONC.
The bill supports physicians who may choose to adopt new payment and delivery models, it also retains a fee-for-service model. Under the model MACRA consolidates a number of reporting programs and offers greater flexibility for physicians as well as reduce burdens. Providers, under the proposal, can choose to get paid under MIPS or certain alternative payments models (APMs).
The rule proposed two types of alternative payment models (APM): Advanced APMs and Other-Payer Advanced APMs. Providers must meet three requirements for each model to be considered eligible.
Requirements include participants to use certified EHR technology and provide payment for covered professional services based on quality measures compared to those used in the quality category of MIPS.
CMS says they considered providers’ concerns about whether they can participate in more than one APM model, stating it proposes “if an individual eligible clinician who participates in multiple Advanced APM entities does not achieve [qualified APM professional {QP}] status through participation in any single APM entity, we would assess the eligible clinician individually to determine QP status based on combined participation in Advanced APMs.”
Notably, the rule states professional services done at critical access hospitals, rural health clinics and federally qualified health centers that meet certain criteria can be counted towards the QP determination.
Visit here for the MACRA proposed rule https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf
