The Centers for Medicare and Medicaid have released the notice of proposed rule-making (NPRM) for the Medicare Access and CHIP Reauthorization Act. The proposed rule was released in late April and the final rule is schedule to be released in the fall of this year (2016). Here is a breakdown of the MACRA NPRM if you haven't yet had the time to read the entire 962 pages.
What is the MACRA NPRM trying to achieve?
MACRA repeals the Sustainable Growth Rate (SGR), streamlines multiple quality reporting programs into the new Merit-based Incentive Payment System (MIPS), and provides incentive payments for participation in Advanced Alternative Payment Models (APMs).
The proposed rule suggests, that the three currently independent programs, will work as one, which should ease the clinician reporting burden. The proposed rule also adds a fourth program that promotes ongoing improvement and innovation to clinical activities.
The four programs and their respective percentages for the proposed rule are below. It should be noted that Meaningful Use has been renamed “Advancing Care Information” (ACI).
- Quality: 50%
- Resource Use: 10%
- Clinical Practice Improvement Activities: 15%
- Advancing Care Information: 25%
When does the rule take effect?
The rule proposes that the first performance period would start in 2017 for payments adjusted in 2019. Keep in mind with the implementation of MACRA and the replacement of the SGR, clinicians participating in MIPS or Advanced Alternative Payment Models of the Quality Payment Program won't all receive enhanced payments for exemplary performance. This is not a stimulus program and some clinicians will see reduced payments for non-performance.
A Look Into Each Performance Category
The proposed rule states that clinicians will be able to choose the measures on which they’ll be evaluated. The number of measures that must be selected was also reduced from 9 to 6 measures.
Clinicians must include 1 cross-cutting measure and 1 outcome measure. If an outcome measure is unavailable then the clinician must choose another high priority measure. Clinicians will be able to select from a list of individual measures or choose from a specialty measure set.
2. Resource Use
The Resource Use category will be determined by comparing resources used to treat similar care episodes and clinical condition groups across all practices. The proposed rule notes that this comparison can be risk-adjusted to reflect external factors.
CMS will calculate this category based on claims so there will not be a reporting requirement for clinicians. The key change made in the proposed rule is an addition of 40+ episode specific measures, which addresses specialty concerns of clinicians.
3. Clinical Practice Improvement
The Clinical Practice Improvement category will include activities such as care coordination, shared decision-making, safety checklists, and expanding practice access. Clinicians must select a minimum of one CPI activity, from a list of 90+ activities, with no additional credit given for additional activities demonstrated.
The proposed rule states that entities acting as a Patient-Centered Medical Home (PCMH) will receive full credit. Also, entities acting as APMs will receive a minimum of half credit.
4. Advancing Care Information (Previously Meaningful Use)
The proposed rule has changed the name of this category from Meaningful Use to Advancing Care Information. There is a total of 131 points available for this category. A base score will account for 50 points of the total ACI performance category score. A performance score will account for 80 points of the total ACI performance score. And the bonus will account for 1 point of the total ACI performance score.
If a clinician earns 100 or more points by combining these three areas then they will receive full credit in the ACI category of the MIPS Composite Score. To receive the base score, clinicians must provide the numerator/denominator or yes/no for each objective and measure.
Image Credit: CMS NPR QPP Fact Sheet
What are the MACRA Advancing Care Information objectives and measures that have replaced Meaningful Use?
CMS has proposed six objectives and their measures that would require reporting for the base score:
- Protect Patient Health Information (Answer of “Yes” required)
- Electronic Prescribing (numerator/denominator)
- Patient Electronic Access (numerator/denominator)
- Coordination of Care Through Patient Engagement (numerator/denominator)
- Health Information Exchange (numerator/denominator)
- Public Health and Clinical Data Registry Reporting (Answer of “Yes” required)
The proposed rule states that scoring in this category is based on key measures of health IT interoperability and information exchange.
The key changes to this program are:
- CMS dropped the “all or nothing” threshold for measurement
- Removed redundant measures to alleviate reporting burden
- Eliminated Clinical Provider Order Entry (CPOE) and Clinical Decision Support objectives
- Reduced the number of required public health registries to which clinicians must report
Questions or Comments About MACRA?
Leave a comment below if you have a question regarding the proposed rule and how it will impact your practice.
We will also be publishing posts regularly to keep you updated on MACRA and providing further details about the Advanced Payment Models (APMs). Subscribe to updates today and receive notifications right to your inbox when these articles are published.
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