CMS acting administrator Andy Slavitt recently suggested in a Senate Finance Committee hearing that MACRA could be delayed. However, whether or not that will happen is still very much up in the air and any delay wouldn't be announced until later this year in the final rule.
It's important to keep in mind that CMS can only delay the performance evaluation period. The start date of payment changes, 2019, cannot be delayed by a CMS ruling, as it is written into the law. However, even if the performance period for MACRA is delayed—perhaps starting July 1, 2017 instead of January 1—providers should not ease up on their preparation efforts.
Clear first-mover advantage
The Merit Based Incentive Payment System (MIPS), the payment track most providers will fall into, is revenue-neutral. This means that the program will produce winners and losers—making it crucial that providers act now to prepare. Eligible clinicians who do not report will receive a 4% payment penalty in 2019, but those who score in the top decile can receive a 4% or higher bonus. Achieving a score in the top of the pack will only become more difficult as other providers make investments and develop the necessary reporting capabilities.
Further, organizations will likely need to undergo significant operational practice changes to achieve high performance scores and earn payment bonuses in MIPS. A delay would provide reprieve for the many providers who are feeling behind, but organizations should take the opportunity to move forward with their preparations now so that whenever MACRA does kick in, they're better set up for success.
We're still heading in the same direction
It's important for providers to understand that MACRA will likely continue to evolve over the next several years, but the direction of change—more payment tied to performance—is pretty certain.
We think the safe bet is not to react to every individual MACRA-related possibility. Instead, the key to succeeding in this dynamic payment framework is to put in place a long-term strategy that prioritizes no-regret investments in performance improvement.
Here's how to prepare for MACRA
Join Advisory Board experts on September 29 to review the critical actions that you can take now, no matter how the final rule shakes out.