At 962 pages, the proposed rule to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) isn't quite as long as "War and Peace," which is 1,225 pages. Still, it's easy to miss what's important in this proposed rule.
For example, if your practice includes nurse practitioners and physician assistants, you'll need to consider whether to "test drive" the Advancing Care Information (ACI) category within the Merit-Based Incentive Payment System (MIPS) in 2017, says Tony Panjamapirom, senior consultant for research and insights at the Advisory Board.
Physicians Practice recently interviewed Panjamapirom to learn what this means for your practice.
Physicians Practice: MACRA's proposed rule involves a lot of reading. What's one thing that physician practices might have missed?
Tony Panjamapirom: In the past, Meaningful Use only applied to physicians. But as of Jan. 1, 2017, the MIPS program also includes some non-physicians, such as physician assistants and nurse practitioners and others. Practices need to start to think about whether these advanced practitioners will be able to meet the ACI requirements, which are the equivalent of the existing Meaningful Use.
If you have nurse practitioners and physician assistants seeing patients, these requirements might introduce new challenges. At least in the first year, these providers can opt in or out to meet the requirements in the ACI category in MIPS. In future years, CMS starts to transition these providers to the mandatory side.
Physicians Practice: What's your advice for practices as they start to bring advanced practitioners into the ACI fold?
TP: These providers weren't eligible to take part in Meaningful Use in the past, so they didn't need to pay attention to the requirements. The majority of advanced practitioners around the country have never seen Meaningful Use before. That's why, since 2017 is an optional year, it's a good thing for practices to use the year as a "test drive." This isn't going to make or break a practice's overall score or an individual provider's score because CMS will reweigh it.
Since it's an optional year, you might want to start training your advanced practitioners in the same way that you have done for your physicians for Meaningful Use purposes. Start tracking their performance on those measures that you're now tracking for your physicians. Look at how they perform and figure out what can be done to improve their performance.
Physicians Practice: Will the end result be greater interoperability?
TP: I think it will. The health information exchange objective that CMS has continued to adopt from Stage 2 and Stage 3 of Meaningful Use will drive toward interoperability among providers and data sharing. And CMS even makes it clear in the proposed rule, which says that the agency will do surveillance on data sharing to make sure that there's no information blocking.