Practice Notes

Concerned about MACRA? You're not the only one.

by Yena Son and Daniel Kuzmanovich

Now that the final Medicare Access and CHIP Reauthorization Act (MACRA) rule is out, how do you feel about your MACRA preparations? We recently surveyed members of the Medical Group Strategy Council to gauge their concern and see how they're adjusting to the changes MACRA will cause.

A group of thirty employed medical groups participated in the survey. Here are the key insights:

Almost three-quarters of respondents are concerned about MACRA implementation

70% of respondents report being "concerned" or "totally freaked out" by MACRA. Of the remaining respondents, 20% are "confident," while 10% are "ambivalent." The overwhelming majority of qualitative responses to the survey suggest that respondents view MACRA as unnecessarily complicated, which will make it difficult to comply with regulations.

The majority of respondents anticipate falling into the MIPS track

The MACRA payment track that medical groups fall into in 2019 depends on their risk model participation in 2017. As only 5% of survey participants anticipate being exempt from MACRA in 2017, the remaining 95% will be split between the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) tracks. The strict requirements for APM participation suggest that the majority of groups will fall into MIPS, and our survey data supports this expectation. A large majority of respondents (70%) anticipate participating in MIPS, while the remaining 25% project they will fall into the APM category.

Readiness for Jan. 1 MIPS-relevant data reporting is only at 50%

Due to widespread concern about being able to comply with regulations, the Centers for Medicare and Medicaid Services (CMS) created multiple data reporting options for MACRA. Providers can report data for all of 2017 to be eligible for a potential positive payment adjustment, or they can partially report for a reduced number of days to be eligible for a smaller positive payment adjustment. Eligible providers also have the option to test MACRA by submitting limited data to avoid a negative payment adjustment. This final data reporting option is designed to let medical groups verify that their system works properly and ensure they are ready for broader participation beginning in 2018.

Of the medical groups that believe they will participate in MIPS, just 50% expect to be ready to report data for the entirety of 2017 (and eligible for a positive payment adjustment). Another 21% anticipate choosing the partial-year option to be eligible for the smaller positive payment adjustment. This leaves a notable 29% of respondents planning to "test the program"—reporting minimal data to avoid the negative payment adjustment.

Respondents had above average participation in alternative payment models

As depicted by the table below, respondents were involved in an array of Medicare payment programs in 2016 and anticipate similar involvement in 2017.

Type of Program
Payment Model
Participation in 2016
Anticipated Payment
Model Participation
in 2017
Medicare Shared Savings (MSSP) ACO, Track 1
26%
26%
Medicare Shared Savings (MSSP) ACO, Track 2 or 3
11%
5%
Next Generation ACO
5%
16%
Comprehensive Primary Care Plus (CPC+)
N/A
37%
A Medicare Advantage Plan
42%
42%
Bundled Payments for Care Improvement Initiative (BPCI)
21%
32%
Comprehensive Care for Joint Replacement (CJR)
11%
6%
Our medical group was not a formal participant
in any of these programs in 2016
21%
N/A

It's too soon to tell on MACRA-inspired consolidation

An initial CMS analysis (found in table 64 of the proposed rule) estimated that, under MACRA, providers in solo practice or small practices (two to nine clinicians) are more likely to receive a negative payment adjustment due to the complexity of the reporting requirements. Similarly, a 2016 survey by Black Book Market Research found that 67% of high Medicare-volume physicians viewed MACRA as a reason to give up their independence.

In our own survey, 58% of respondents noted that MACRA was the impetus for consolidation efforts in their markets. Some were initiating the conversation to acquire or merge with other groups, while others were evaluating innovative alignment models with other organizations.

However, the other 42% of our survey's respondents report that they have not observed MACRA affecting consolidation decisions in their markets. This could be a result of the additional support for small practices CMS included in the final rule. But we're still in the early stages of MACRA implementation, so this may change during the coming year.

Can we help set you up for MACRA success?

Our one-day MACRA intensive provides both industry-wide best practice research and organization-specific strategic guidance to help you navigate this transition and ensure future success in the new health care environment.

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