MACRA provides two tracks for providers: The Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). To start preparation for MACRA, you should educate and discuss the new regulations by participating and attending professional organization meetings where thought leaders discuss the two tracks. You should also evaluate individual quality measures identifying areas of high performance, as well as reviewing Quality and Resource Use Reports. If not currently reporting Meaningful Use (MU) and the Physician Quality Reporting System (PQRS), you need to evaluate potential penalties and their readiness for MACRA.
The first decision for physicians would be determining which track you or your group would choose as it will impact the transition from a fee-for-service healthcare system to an APM that rewards quality of care over quantity of services. The MIPS path provides for reduced existing requirements by combining three existing quality programs into one—MU, PQRS and the Value-based Payment Modifier (VPBM). MIPS allows for flexible performance and time to prepare for participation in the system by combining weighted score of quality, resource use, MU and clinical improvement activities to determine how payments will be adjusted.
The APM track would be best for clinicians already participating in alternate accountable care organizations (ACOs) and patient-centered medical homes, and would provide more generous incentive programs that are exempt from MIPS requirements. Physicians will need to determine how they would meet MIPS or APM reporting requirements to evaluate qualification for bonus payments.
Physicians can also prepare for MACRA by:
Determine if you are exempt from participating. You may be one of the many physicians who might be exempt from penalties for not participating in MIPS. The Centers for Medicare & Medicaid Services (CMS) has developed a low-volume threshold exemption from the MIPS program. Courtesy of the Harris County Medical Society here in Houston, you can check eligibility here: http://tinyurl.com/zgxgk6r.
Reviewing the timelines. The first performance period for MIPS begins on Jan. 1, 2017. This means that every eligible clinician will need to be sensitive to MIPS reporting and documentation requirements now as performance in 2017 will affect clinician reimbursement in 2019.
Determining eligible clinicians (ECs). MACRA defines additional types of providers compared to Meaningful Use so clinicians should not assume that because they were not included in Meaningful Use that they will also not be subject to MIPS.
For 2017, eligible clinicians for MIPS include:
- Physician assistants
- Nurse practitioners
- Certified registered nurse anesthetists
- Clinical nurse specialists
Understanding the basics—MIPS vs. APMs. For 2017, CMS is forecasting that 87% of ECs will need to report on MIPS. Only “qualifying participants” (QPs) in Advanced APM will not need to report using MIPS; yet, CMS will not make the determination of who is a QP until July 2017 at the earliest.
This means that all ECs should be prepared to report using MIPS for 2017.
Determining vendor support. MIPS data will be able to be submitted via relevant third-party intermediaries (including EHR vendors) in order to help providers with attestation. ECs should contact their EHR vendor to understand their plans to support MIPS and MIPS attestation, and the timelines for availability of any required software updates.
Staying informed. Review the CMS’ website (https://qpp.cms.gov/) and subscribe to news updates.