Slavitt Says Final MACRA Rule Proves CMS Listened

Center for Medicare and Medicaid Services (CMS) Acting Administrator Andy Slavitt points to the agency’s recent MACRA final rule as an example of how it’s listening to healthcare stakeholders. His comments were made in a recent blog.
The final rule for the Medicare Access and CHIP Reauthorization Act of of 2015 (MACRA), released Oct. 14, charts a path for implementation of the law, which replaced the troublesome Sustainable Growth Rate method of provider payment. The 1200-plus page rule includes a number of changes from the proposed rule, many of which reflect comments the agency received this summer.

Pay for What Works

Slavitt writes that patients want CMS to pay for “what works” and for higher-quality outcomes and clinicians want to focus on delivering the best care for patients without being burdened by reporting and paperwork. He points out the final rule reduces the number of required measures and providers  will enjoy more flexibility to select he measure they believe best represents patients’ needs.
And even though the program starts January 1, 2017, Slavitt points to very few changes through 2018, especially if a provider already participates in an an Advanced Accountable Payment Model (APM). More options for participating will come, he wrote. “The first couple of years are aimed at getting physicians gradually more experienced within the program and vendor more capable of supporting physicians.”
Providers also have the opportunity to select one of four ways to adopt MACRA in 2017:

• First Option: Test Quality-based Payment –  With this option, as long as the provider submits some data to the Quality Payment Program, including data from after Jan. 1, 2017, the provider avoids a negative payment adjustment. This option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.
• Second Option: Participate for part of the calendar year – Providers may choose to submit quality-based payment information for a reduced number of days. The first performance period may begin later than Jan. 1, 2017, and the practice could still qualify for a small positive payment adjustment. Information submitted for part of the calendar year for quality measures, how the  practice uses technology, and what improvement activities are being undertaken, providers may qualify for a small positive payment adjustment. Providers can select from the list of quality measures and improvement activities available under the Quality Payment Program.
• Third Option: Participate for the full calendar year – Providers ready to go on Jan. 1 may choose to submit quality-based payment information for a full calendar year. The first performance period would begin on Jan. 1, 2017. Providers who submit information for the entire year on quality measures, how the practice uses technology, and what improvement activities are being undertaken may qualify for a modest positive payment adjustment.
• Fourth Option: Participate in an Advanced Alternative Payment Model in 2017 – Instead of reporting quality data and other information, the law allows providers to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If a provider receives enough  Medicare payments or see enough Medicare patients through the Advanced Alternative Payment Model in 2017, then the provider qualifies for a 5 percent incentive payment in 2019.

Providers will enjoy a 0.5 percent fee schedule update across the board over the next two years, and Slavitt says CMS left the comment period open so the final rule can be adjusted as it is implemented.

Joining APMs

CMS feels that MACRA works better if physicians particpate in APMS, so it’s offering a number of types of APMs to providers. In 2017, under the Quality Payment Program, clinicians may earn a 5 percent incentive payment through sufficient participation in the following Advanced APMs:

• Comprehensive ESRD Care Model (Large Dialysis Organization (LDO) arrangement)
• Comprehensive ESRD Care Model (non-LDO arrangement)
• CPC+
• Medicare Shared Savings Program ACOs – Track 2
• Medicare Shared Savings Program ACOs – Track 3
• Next Generation ACO Model
• Oncology Care Model (two-sided risk arrangement)

In 2018, we anticipate that clinicians may also earn the incentive payment through sufficient participation in the following models:

• ACO Track 1+
• New voluntary bundled payment model
• Comprehensive Care for Joint Replacement Payment Model (Certified Electronic Health Record Technology (CEHRT) track)
• Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT track)

These lists will continue to change and grow as more models are proposed and developed in partnership with the clinician community and the Physician-Focused Payment Model Technical Advisory Committee.

Adapting MACRA for Small and Rural Practices

Slavitt writes that CMS seeks to aid small practices by reducing the time and cost to participate, excluding more small practices, increasing the availability of Advanced APMs to small practices, allowing practices to begin participation at their own pace, and other means. The agency plans to spend $20 million a year over the next five years to provide technical support and outreach. While CMS expects to exempt 380,000 providers, the agency hopes to have similar participation in small and rural practices as in larger, more urban settings.s

Merit-Based Incenter Payment System (MIPS) Simplified

Slavitt promises simplified scoring, better feedback and clear rules, which are manifested by simplifying requirements for quality measures and practice-specific improvement activities.  CMS also, he wrote, moving the measurement of certified electronic health record (EHR) technology with the improvement activities. Beginning in 2017, CMS will start with a portion of the Advancing Care Information measure than align more of those measure with quality in later years. Hoping to assure certified EHRs are being used to support high-qulity care, Slavitt writes that CMS has narrowed the focus of measures supporting facility and physicians so they can safely and easily exchange information.

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Brad Ericson

Director of Publishing at AAPC

Brad Ericson, MPC, CPC, COSC, is a seasoned healthcare writer and editor.He directed publishing at AAPC for nearly 12 years and worked at Ingenix for 13 years and Aetna Health Plans prior to that. He has been writing and publishing about healthcare since 1979. He received his Bachelor's in Journalism from Idaho State University and his Master's of Professional Communication degree from Westminster College of Salt Lake City.

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