The general consensus among analysts and consultants is that with the final rule for the Medicare and CHIP Reauthorization Act (MACRA), the Centers for Medicare & Medicaid Services (CMS) took a step in the right direction by easing and lengthening the runway into the program. Providers need only report one measure for a minimum 90-day period to avoid a penalty for 2017. If nothing else, the move indicated that CMS heard the concerns voiced by physicians and health systems about the proposed rule.
Nevertheless, the overall complexity of the shift to value-based payment over the next few years will leave many physician practices with difficult or confusing decisions about how to approach the Merit-based Incentive Payment System (MIPS). The pathway combines the Physician Quality Reporting System, Meaningful Use, and Value-Based Payment Modifier into one program. MIPS’ four components are Quality, Resource Use, Clinical Practice Improvement Activities, and Advancing Care Information. The program is designed to allow physicians to choose the measures most meaningful to their practice.
Physicians also must look ahead at Advanced Alternative Payment Models (APMs), such as Comprehensive Primary Care Plus, which offer 5 percent bonuses and streamlined quality reporting, but also require practices to take on downside risk and upfront infrastructure costs.
Physicians Practice asked several experts to describe what they think will be the greatest challenges for practices as they enter MACRA territory in 2017.
MIPS or Advanced APMs?
CMS has given practices an option of doing very minimal levels of reporting to avoid a penalty for 2017. Martie Ross, a principal in the Kansas City office of consulting firm, Pershing Yoakley & Associates (PYA), says that by far the easiest way to check the box for 2017 is to report one clinical practice improvement activity. "You should fire your practice manager if he or she can't figure out how to get you full points on Advancing Care Information and Clinical Quality Improvement Activity," she says.
But Ross added that practices should ask themselves the following question: Does it make sense for us to simply check the box in 2017, then focus our energies on more long-term strategies? For example, CMS promises to open up enrollment in Advanced APMs significantly for 2018 reporting. "You could develop lots of infrastructure to do quality reporting for MIPS or you could spend time evaluating Advanced APM options for your practice," she says. "If you think you are in a position to do well by these MIPS metrics, and you can identify the right measures and earn a bonus, then it is definitely worth the effort. But if it is a matter of positioning your organization more broadly for value-based reimbursement, I don't know that just dotting the i’s and crossing the t's on MIPS is going to get you there."