The Centers for Medicare & Medicaid Services (CMS) said last week that more changes will be coming this year to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)—including the alignment of quality measures between hospitals and hospital-employed physicians.
Kate Goodrich, M.D., director of the Center for Clinical Standards and Quality and the chief medical officer at CMS, said at a meeting last week in Washington, D.C, as reported by the Healthcare Financial Management Association (HFMA), that the lack of that quality measurement alignment has hindered quality reporting during the first years of the MACRA law.
“The measures are basically the same, but what people have to do—the rules of the road, if you will—on the scoring are very different between the two,” Goodrich said, referring to hospitals and their employed physicians. “And that creates problems for health systems that use a single [electronic health record (EHR)] to report on behalf of clinicians and to report on behalf of hospitals,” she said, as reported by HFMA.
Indeed, the implementation of facility-based scoring by CMS would aim to help physicians who want to use their hospital’s quality-measure performance for reporting under one of MACRA’s payment tracks—Merit-based Incentive Payment System (MIPS). “This gets to an alignment of incentives between hospitals and the clinicians who work in those hospitals in terms of what they are focused on for improvement and ultimately for accountability,” Goodrich said at the meeting.
Goodrich also brought up the Bipartisan Budget Act of 2018 (BBA), noting that CMS is looking at “overhauling” MACRA—including through simplification of the data submission process, per the legislation. Specifically, CMS is looking at each quality measure that physicians are required to report under MACRA and will consider dropping any measure that is underperforming or “topped out.”
As Healthcare Informatics reported last month, as part of the BBA, lawmakers proposed that for each of the second, third, fourth and fifth years for which MIPS applies to payments, a clinician’s cost-cutting would never be less than 10 percent and never more than 30 percent. In other words, the “Cost” category of MIPS—one category that determines a clinician’s final MIPS score—could be weighted at just 10 percent through 2021, given this new legislation. As per the MACRA 2018 final rule that was released last fall, CMS had originally intended to have the Cost category jump from 10 percent of a clinician’s score in 2018 all the way up to 30 percent of the overall score in 2019.
At the core of these approaches, noted Goodrich, is to reduce the regulatory burden that MACRA/MIPS places on providers. “We continue to hear that the program is still too complicated,” Goodrich said. “People are glad we’ve allowed for a lot of flexibilities, but what that does is makes things complicated. We’ve gotten some very specific ideas about ways we can further simplify the scoring in some of the policies.
As the HFMA report noted, the BBA included other important provisions for MIPS, removing Medicare Part B drug costs as a factor in MIPS payment adjustments and in low-volume threshold determinations for required MIPS participation. CMS plans to update by the end of March which physicians will be required to report under MIPS.
The administration also is working with EHR vendors and registries to search for ways to automatically extract required quality data from electronic records with little or no action required by physicians.
Nonetheless, these efforts will not produce another delay in implementing requirements that providers adopt 2015-edition EHR technology as part of the EHR meaningful use program. “We’ve delayed this a couple years, but last year we finalized that this would be required starting in 2019; we are not backing down on that, so we are not changing that and will reiterate that" in upcoming payment rules, Goodrich said, per the HFMA report.
Goodrich also affirmed the administration’s position on moving more physicians into advanced APMs (alternative payment models) as part of MACRA. This continues as a “top strategic goal” of CMS, she said.