In the week since CMS released its proposed rule to implement MACRA's Quality Payment Program (QPP), our experts have analyzed the 1,000+ pages. They plan to share key insights and action items their upcoming webconference on Tuesday, July 11 at 3 p.m. ET. (Register now to secure your spot).
Here's a sneak peek of their reactions to the rule:
Rob Lazerow, Managing Director, Health Care Advisory Board
This proposed rule provides even more evidence that payment reform remains one of CMS's primary goals and that new payment models are gaining traction with providers.
After factoring in the latest models and application periods—especially MSSP Track 1+, the Next Generation ACO Model, and the CPC+ program—CMS now expects that up to 245,000 providers will qualify for the Advanced Alternative Payment Model (APM) Track based on their 2018 participation decisions. That's double CMS's 2017 projection.
Perhaps even more important, MACRA is already encouraging providers to push beyond the upside-only risk models that initially dominated the Medicare ACO landscape. The number of Medicare ACOs participating in downside risk models has more than doubled from 2016 to 2017, reaching 87 this year. I expect this migration to downside risk will continue as more providers reach their MSSP renewal dates, especially since CMS is proposing to maintain the current standard for payment models to count toward the Advanced APM track through 2020. By law, payment models must impose more than a "nominal amount" of risk to qualify.
Overall, the proposed rule gives providers renewed clarity that they must develop an intentional Medicare risk strategy to successfully prepare for MACRA.
Hamza Hasan, Practice Manager, Medical Group Strategy Council
The proposed creation of a path for facility-based clinicians to participate in the Merit-based Incentive Payment System (MIPS) is a significant development.
By allowing clinicians to use their facility's value-based purchasing (VBP) score, CMS would finally be making the connection between MACRA's QPP and inpatient VBP performance. This would accomplish two goals. First, it would expand the options these eligible clinicians have to successfully participate in the QPP. Second, and perhaps more importantly, it would create a direct connection between physician performance metrics and the hospital-based pay-for-performance (P4P) programs. The necessity of ensuring strong alignment with facility-based clinicians means hospital leaders would have an even stronger incentive to focus on improving P4P performance.
Separately, some providers in the MIPS track might see the proposed rule as an excuse to pull back from cost-control efforts—but that would be a mistake. While the proposed rule would zero out the cost category under MIPS for 2018, that wouldn't last long. Under the MACRA law, the cost category must account for 30% of the MIPS score by the 2019 performance year. That's a big jump and providers should use the coming year to prepare.
Naomi Levinthal, Practice Manager, Health Care IT Advisor and Quality Reporting Roundtable
CMS pumped the brakes on its plan to require QPP participants to upgrade their Certified EHR Technology (CEHRT) in 2018.
The news isn't entirely surprising, since CMS this past April in its 2018 Inpatient Prospective Payment System (IPPS) proposal floated doing the same for hospitals that participate in the Inpatient Quality Reporting and Meaningful Use (MU)—although the agency did not go so far as to formally propose it.
Should CMS choose not to align the CEHRT requirements between IPPS and QPP, health systems that manage both hospital and ambulatory quality programs would have to monitor very different sets of requirements. Additionally, health systems would have to choose between an accelerated CEHRT upgrade timeline for all providers or a competing timeline across programs.
Krista Teske, Consultant, Physician Practice Roundtable
In last year's QPP rulemaking cycle, it became abundantly clear that smaller groups were not likely to fair well under MIPS. Recall that CMS estimated that 42% of groups with one to nine eligible clinicians would receive a negative payment adjustment under the program.
This time around is a different story: The 2018 proposal shows CMS is dedicated to leveling the playing field for smaller groups. They propose doing so in two key ways:
- By making it easier for smaller groups to meet the MIPS requirements by giving them preferential treatment in certain MIPS categories and adding virtual groups as a participation option; and
- By increasing the threshold of Part B patients or charges necessary for an eligible clinician or group to be subject to MIPS from ⋜$30,000 in Part B allowed charges or ⋜100 Part B beneficiaries to ⋜$90,000 in Part B allowed charges or ⋜200 Part B beneficiaries.
But if providers think they could get away scathe-free and avoid MIPS altogether because of these elevated thresholds, they should think again.
It is important to remember that these thresholds would apply to individual providers OR groups of providers. That means that if a group is reporting as a group under MIPS and the entire group has more than $90,000 in Part B charges or more than 200 Part B beneficiaries, then the entire group would be subject to MIPS. Therefore, the only providers this new proposal actually helps would be those reporting individually. Many providers that are part of medium-to-large medical groups or systems have already migrated to group reporting so, these thresholds may have less of an impact on the number of providers subject to MIPS than you might expect.
It's also likely that these thresholds would cut the portion of MIPS eligible clinicians that would have otherwise been unable to meet the MIPS requirements, resulting in an even more competitive MIPS landscape. This could result in lower bonuses for the higher performers and a narrower spread between high and low performers.
Kathryn Martucci, Senior Analyst, Health Policy
This was one of the first opportunities for the new administration to put its mark on the future of payment reform, and they proposed leaving the structure of MACRA's QPP intact. In fact, the proposed rule would offer significant flexibility and give clinicians even more ways to succeed in the program.
The new administration—most notably, HHS Secretary Tom Price—had previously expressed conflicting views about MACRA. While Price voted in favor of the passage of MACRA in 2015, he was also somewhat critical of the law's implementation in its first year and expressed concerns about the rapid pace at which the Obama administration had pressured providers to take on risk.
However, the content of this rule, along with the fact that Price has maintained implementation of other payment reform initiatives, such as the Medicare Shared Savings Program and The Center for Medicare & Medicaid Innovation's (CMMI) programs, gives us even more confidence that payment reform will continue during his tenure.
Join us to learn more key insights and action items from the MACRA proposal
On July 11 at 3 p.m. ET, our experts will give an overview of the most important implications of the proposed rule; review key changes to the MIPS and APM tracks for the 2018 performance year; and provide guidance on navigating the transition to risk-based payment and the evolution of hospital-physician alignment.
You won't want to miss this webconference—so register now to secure your spot.
Electronic Medical Records Strategy,
Promoting Interoperability (formerly Meaningful Use),
Standards and Regulatory Policy,
Cost and Productivity,
Shared Savings Model,