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MACRA – The implication of MIPS for your practice

In last month’s newsletter we provided an overview of MACRA and discussed the two payment methods for eligible providers – Merit-based Incentive Payment System (MIPS) track and Alternative Payment Model (APM) track. The Centers for Medicare and Medicaid Services (CMS) estimates that only 4.5% - 12% of clinicians are projected to qualify for the APM track in 2019.  Given this projection, it’s important to build your understanding of MIPS and the implications for your practice. This second article will go into more detail on the MIPS track.

This article includes a number of terms you may not be familiar with. See the “Definitions” section below.

Beginning January 1, 2019, eligible professionals (EPs) who practice predominantly through fee-for-service (FFS) models will participate in the MIPS payment track. Medicare reimbursement for MIPS EPs will be subject to a MIPS Adjustment Factor based on a Composite Performance Score, to be calculated based on performance in four weighted categories: quality, resource use, clinical practice improvement and advancing care information. The initial MIPS Performance Period will begin on January 1, 2017, with performance measurements used to calculate the 2019 Composite Performance Score expected to be taken between January 1 and December 31, 2017.

In 2019, MACRA sunsets the payment adjustments associated with the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VBM), Meaningful Use, and other physician measurement programs. The new program is composed of four weighted MIPS Performance Categories:

Quality – 50% weight initially, decreasing to 30%
  • Published annually and will emphasize outcomes, patient experience and care coordination.
  • There will be more than 200 measures to choose from, 80% tailored to specialists. Measures currently in PQRS will likely continue on in the early years of MIPS.

Resource Use – 10% initially, increasing to 30%
  • Score based on Medicare claims; no reporting requirement for clinicians.
  • CMS will use per-patient total allowed charges for all services under Medicare Part A and Part B for the analysis of resource use, and may also incorporate Part D charges.

Clinical Practice Improvement – 15% weight

  • Clinicians are rewarded for clinical practice improvement activities such as activities focused on care coordination, beneficiary engagement and patient safety.
  • There will be over 90 activities to choose from; some are weighted higher than others and those clinicians in certain APMs will receive favorable scoring.

Advancing Care Information – 25%
  • Replaces the Meaningful Use program and applies to all clinicians.
  • No longer requires all-or-nothing reporting and requires fewer measures.

CMS will calculate a composite assessment, using a scoring scale of 0 to 100, which is referred to as the Composite Performance Score. The score for each MIPS provider will be publicly reported through the CMS Physician Compare website.

Summary
  • MACRA repeals and replaces the Sustainable Growth Rate (SGR).
  • Good news: MACRA will replace PQRS, Meaningful Use, VBM and other Medicare payment programs.
  • Bad news: MACRA is complicated with two separate payment tracks and requires continued focus on quality measurement and reporting, performance improvement, electronic adoption and cost management.
  • Important news: The first performance period is expected to begin January 1, 2017.  The final rule may change the timeline, but practices need to prepare as if it is starting in the new year.
  • What you can do: Check with physician and specialty associations and with your EMR vendor to better understand their strategies for success with quality measurement and reporting.

Stay tuned for next month’s newsletter to learn how your MIPS Composite Performance Score ties in to payment adjustments.

Definitions

Key MIPS track terms include: 

MIPS Eligible Professional (MIPS EP): Initially to include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. 
Performance Category: Domains used in the calculation of the Composite Performance Score, to include quality, resource use, clinical practice improvement, and meaningful use of certified EHR technology. 
Performance Period: A performance period of one year, which begins and ends prior to the beginning of the year in which MIPS EP reimbursement will be impacted. 
Composite Performance Score: A methodology for assessing the performance of each MIPS EP over a Performance Period. Using the assessment methodology, CMS will provide each MIPS EP with a score on a scale of 0 to 100. 
MIPS Adjustment Factor: An adjustment applied in the form of a percent to the Medicare reimbursement of a MIPS EP based on the Composite Performance Score.

Sources: The Advisory Board and The Academy Advisors

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