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New MACRA Options Offer Revenue Cycle Relief

September 20, 2016

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Physician practices are breathing a bit easier thanks to the recent announcement that CMS will offer providers leeway in the process of adopting new Medicare reimbursement models slated to kick off on January 1, 2017.

The Medicare Access and CHIP Reauthorization Act (MACRA), which is slated for final rule this fall, replaces former Sustainable Growth Rate (SGR) reimbursement provisions in favor of a new payment model centered on pay-for-performance and designed to promote better quality of care. Under the new framework physicians have two new reimbursement program paths.

The Merit-based Incentive Payment System (MIPS) combines three existing healthcare incentive programs – the Physician Quality Reporting System (PQRS), the Meaningful Use/EHR incentive program and the Value-based Payment Modifier (VBM) – into a new composite performance score. Based on how eligible professionals (EPs) fare, they will receive either a bonus, a penalty or no adjustment on Medicare payments.

Alternative Payment Models (AMP) will offer qualifying providers annual payment bonuses when physicians earn significant revenue or see sufficient patient percentages through qualifying Medicare or payer models, requiring the acceptance of some financial risk if spending surpasses targets. Accountable Care Organizations (ACOs), Patient Centered Medical Homes and bundled payment models are some APM examples.

Industry stakeholders anticipate that roughly 90 percent of providers will initially report under MIPS. Medicare payment adjustments under MACRA will begin in January 2019.

In light of the complexity of new MACRA programs and corresponding physician concern, this September, CMS introduced new participation options allowing clinicians to pick their own pace for the first performance reporting period.

Option 1 – System Testing:  Submit some data from after January 1, 2017 to the Quality Payment Program (QPP) and avoid a negative payment adjustment.

Option 2 – Partial Period Reporting:  Submit QPP data for a reduced number of days (later than January 1, 2017) to potentially qualify for a small positive payment adjustment.

Option 3 – Full Year Reporting:  Submit QPP data for the full calendar year, beginning January 1, 2017, to qualify for a modest positive payment adjustment (business as usual under MIPS).

Option 4 – Advanced APM:  Participate in QPP reporting via an Advanced APM to qualify for a five percent incentive payment when you meet required Medicare payment or patient thresholds.

The CMS “pick your pace” MACRA move echoes the grace period extended to providers during the industry’s transition to ICD-10 and should go a long way to quell physician fears around adopting the new payment reform model. Per CMS, “Choosing one of these options would ensure [Eps] do not receive a negative payment adjustment in 2019.”