On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) issued its eagerly awaited proposed rule to implement key provisions of the Medicare Access and Summary CHIP Reauthorization Act of 2015 (MACRA).
Passed with broad bipartisan support, last year’s MACRA legislation repealed the Sustainable Growth Rate formula and accelerated the move to a new value-based payment system. This latest proposed rule from HHS outlines the implementation of the MACRA law, including a new “Quality Payment Program” with two available paths for providers:
- Merit-based Incentive Payment System (MIPS)
- Alternative Payment Models (APMs)
MIPS
Under MIPS, eligible providers would earn a composite score based on performance in four categories. This structure consolidates the three existing quality incentive programs (PQRS, Value-based Modifier and Meaningful Use) and a new Clinical Practice Improvement. The categories and their relative weight in year one are as follows:
- Quality: 50 percent
- Advancing Care Information (formerly EHR Meaningful Use): 25 percent
- Clinical Practice Improvement Activities: 15 percent
- Cost or Resource Use: 10 percent
It also is worth noting MIPS focuses on the use of certified electronic health records through the Advancing Care Information (ACI) Program, the renamed Meaningful Use Program, intended to “support the vision of a simpler, more connected, less burdensome technology” with more flexibility for providers. Both the proposed rule and this CMS blog outline the revised framework. CMS also has issued the MIPS/Advancing Care Information Fact Sheet.
APMs
The proposed rule gives eligible providers the choice to pursue a more risk-based pathway by participating in Alternative Payment Models (APMs). This would exempt the “qualifying participant” from the MIPS payment adjustments and allow them to qualify for a five percent Medicare Part B incentive payment.
These APMs are defined under the law as the CMS Innovation Center models, Shared Savings Program tracks, or other demonstrations where clinicians accept both risk and reward for providing coordinated, high-quality and efficient care.
The proposed rule includes the following list of approved models:
- Comprehensive ESRD Care Model (Large Dialysis Organization arrangement)
- Comprehensive Primary Care Plus (CPC+)
- Medicare Shared Savings Program—Track 2
- Medicare Shared Savings Program—Track 3
- Next Generation ACO Model
- Oncology Care Model Two-Sided Risk Arrangement (available in 2018)
CMS proposes to update this list annually, adding new payment models that qualify as APMs and has left the door open for incentive payments based on participation in non-Medicare models.
Impact for NextGen Healthcare clients
The use of EHR technology and meeting quality measurement criteria are mandatory in both the MIPS and APM pathways. The first Quality Payment Program performance year under the proposed MACRA rule would be 2017. Therefore, it is essential clients focus on meeting Meaningful Use and PQRS requirements in 2016. Furthermore, clients should begin to understand the practice and technology implications of both Clinical Practice Improvement Activities (under the MIPS pathway) and the various Advanced APM models (under the APM pathway).
NextGen Healthcare is working on educational webinars and other resources to assist clients in learning more about the MACRA proposal. We also will submit public comments supporting certain aspects of the proposal, while offering constructive suggestions to CMS on how to improve the rule for the benefit of providers. At the same time, we are looking carefully at the rule as we prioritize new enhancements, features and product and service offerings that will help our clients to succeed in the post-MACRA, value-based healthcare market.
More information on the MACA proposal
Health Reform Simplified webinar on proposed MACRA rule – May 18 Register now.
Also…
Proposed Rule
CMS fact sheet
NextGen Healthcare blog