CMS Announces New Flexibility with MACRA

By: Mike Segal

It is now quite clear that the Medicare Access and CHIP Reauthorization Act, or MACRA, enacted into law in 2015, will have a telling effect on how Medicare reimburses for physician services.

In April 2016, the Centers for Medicare & Medicaid Services (CMS) released a voluminous proposed rule for implementing MACRA.  The full implementation of MACRA, with monetary bonuses and penalties, will not occur until 2019.  However, the proposed rule made clear that 2019 results for MACRA’s MIPS model (where it is estimated that more than 90% of all physicians will be placed at the inception of MACRA) would be based on physician performance in 2017.  Thus, every Medicare provider physician in the country was expected to get ready for 2017 in very short order.

CMS gave stakeholders until the end of June to comment on the proposed rule. The final rule was, and is still, expected to be released by November.

Heavy among the comments was that physicians would have great difficulty being ready by 2017.  Many asked that the implementation of MACRA be delayed.

Responding to these comments, on September 8, in the CMS Blog (talk about 21st Century – to be update you must keep your eye on the CMS blog!), Andy Slavitt, Acting Administrator of CMS, announced some new flexibility in the pace of MACRA reporting for 2017.   The blog now provides four options, two of which are new:

  1. Option One – So long as the provider submits some data to the CMS Quality Payment Program (QEP), including data from after 2016, there will be no payment penalty imposed for 2019 (NOTE: no definition of the word “some” was provided – presumably that will come later).
  2. Option Two – If the provider only elects to participate for 2017, and report information to the QEP, for a certain amount of days, it may qualify for a small bonus.
  3. Option Three – The provider may report in full for 2017, as originally anticipated.
  4. Option Four – The provider may participate in MACRA’s APM model, for practices willing to accept some considerable risk, for 2017.

It is important to note that CMS is only providing the new options for 2017. It still expects all providers to be able to fully report by 2018.

In addition, given the fact that the MPIS model is to be budget neutral, taking potentially negative practices off the grid almost certainly means that the MPIS or APM bonuses, or both, will be reduced for 2019.

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