The early returns on CMS' 2,000+-page final rule for implementation of the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) are in.
Experts like many of the changes they saw from the proposed rule, but still seek more changes to ensure small practices don't get left behind. The "pick your own pace" provision, which increases the likelihood that providers will avoid a penalty in 2019 for their performance next year by simply submitting some data to adhere to MACRA guidelines, has been widely praised. So too has CMS raising the low volume requirements, giving more practices the ability to exempt out of MACRA's Merit-based Incentive Payment System (MIPS) altogether.
"[CMS] made a number of changes in an effort to make sure that small practices will not only be able to participate, but also avoid the penalty and in some cases get a bonus. We appreciated CMS raised the low-volume requirements so more small practices will be excluded and don't get penalties," says Danielle Lloyd, vice president of policy and advocacy at the Charlotte-based Premier Inc., a company that provides group purchasing organization services to providers.
Because of these changes, CMS indicated 90 percent of all MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment in the first year. Specifically, CMS says that 80 percent of small practices with one to nine physicians will receive a positive or neutral payment adjustment. In the proposed rule, CMS estimated 87 percent of small practice physicians would be penalized in 2019 for their performance in 2017.
Yet despite this short-term optimism, many were concerned over the long-term prospects of small practices in MACRA. Anders Gilberg, senior vice president of government affairs at the Medical Group Management Association, said that just because it's easier in 2017 doesn't mean physicians are out of the park. "Don't lose sight of the scope, weight, and complexity of what's to come," he says. While 2017 is a unique year and gives practices a reprieve, he says, 2018 is a "must do everything" year.
Gilberg expressed disappointment with CMS continuing to implement a two-year gap between the performance and payment periods. He calls it a fundamental problem with MACRA because it doesn't give them actionable feedback until the midway point of the year between the performance year and the payment adjustment year.
"If you see a patient in January 2017, you are not going to get feedback until mid-2018 on your quality. There is nothing actionable about the information flowing back from Medicare and the physician. This makes it so this regulation still has a compliance element as opposed to an integrated feedback loop that helps move the bar on quality and cost," he says.
Blair Childs, senior vice president of public affairs at Premier Inc., says there is path that small-practice physicians can take to successfully adhere to MACRA and his colleague, Lloyd agrees. He recommends that small practices join a clinically integrated network. Not only will that ease the administrative burden, while allowing the practice to maintain independence, it will also help that practice move towards joining an Advanced Alternative Payment Model (APM).