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12 things you should know about the final MACRA rule

On November 2, the Centers for Medicare & Medicaid Services (CMS) released the final rule for the Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act (MACRA). This significant regulation is shifting the healthcare reimbursement model from volume-based payments to a more comprehensive value-based framework.

This final rule with comment period holds a few surprises, but mostly delivers what was proposed last spring. CMS has largely responded to the concerns of participants and is trying to make the transition less burdensome for clinicians. Here are a few of the highlights:

Merit-based Incentive Payment System (MIPS)

1. For 2018, clinicians can use 2014 Edition Certified EHR Technology (CEHRT), 2015 Edition CEHRT, or a combination of the two for the Advancing Care Initiative (ACI). Note that exclusively using 2015 CEHRT will garner an extra 10 ACI points.

2. The minimum reporting period for ACI in 2018 and 2019 will be 90 days. The same is true for Improvement Activities, but Quality Measures and Cost will have full-year reporting periods.

3. CMS defined a process for proposing Improvement Activities. There were some changes and additions to Quality and Improvement Activities measures.

4. CMS made several accommodations for smaller, rural and specialty practices. For example, it raised thresholds for participation, which will reduce the total participation in MIPS by about a quarter.

5. The “pick your path” option won’t continue in 2018. This option previously allowed participants to submit a small amount of data in exchange for a guarantee of no penalty. However, the amount of data necessary to achieve that shield was raised from a minimum of 3% to 15% -- and achieving 15 points will be easy.

6. CMS will not revoke the Cost measure for 2018. This means that 10% of the final MIPS score will come from up to ten measures calculated by CMS based on submitted claims.

7. There is an optional special hardship exception for participants in areas affected by this year’s hurricanes (and other natural disasters). Those who claim it will be exempt from penalties and incentives.

8. Small groups, including solo practitioners, can form virtual groups in 2018. However, the application deadline is December 1, 2017 and the effort to apply is significant.

Advanced Alternative Payment Models (APM)

9. As predicted, CMS introduced a new version of the Medicare Shared Savings Program (MSSP). This new model, called Track 1+, will include sufficient risk sharing to qualify it as an Advanced APM.

10. The Comprehensive Primary Care Plus program (CPC+) saw an important change which will make all new participants eligible for its rather substantial incentives. 

Providers Fee Schedule (PFS) – Updates to related programs

11. CMS has postponed the “Appropriate Use Criteria for Advanced Diagnostic Imaging Services” program (AUC) program for one year. Voluntary participation will begin on July 1, 2018, and mandatory participation will begin on January 1, 2020.

12. There were significant changes to the Medicare Diabetes Prevention Program (MDPP) expanded model. Comprising nearly a third of the PFS final rule, it delays the start date to April 1, 2018. It also changes the way patients may virtually participate, the set of services that may be offered and the way services are paid for.

There are more changes than those we mention here. We will produce more in-depth assessments of these rules soon. In the meantime, we recommend focusing on a successful completion of 2017 and ensuring that eligible clinicians are preparing to make the move to workflows required under the measures supported by the 2015 Edition CEHRT. 

To learn more, I encourage you to explore these resources:

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