By Michael Pinnolis, MD
Chief Medical Officer, ICP

Most of you are probably aware, to some degree or another, that MACRA (Medicare Access and CHIP Reauthorization Act), the new Medicare payment model from CMS, begins in 2017. Some of you may have already been preparing.. Others of you may not be quite certain what this is all about or were hoping this wouldn’t really affect you. Some of you may have heard that MACRA was postponed or even cancelled.

Do not be lulled into complacency whatever you may think you heard: MACRA is here, and it is most definitely not going away.

MACRA was authorized by Congress in mid-2015 and was approved by a large, bipartisan majority in both houses. It was designed to bring Medicare costs under control and to replace the failed SGR model for cost containment. MACRA was NOT part of the Affordable Care Act (ObamaCare), so the recent Presidential election will not likely have any impact on the MACRA requirements.

Most providers will be in the so-called MIPS (the Merit-based Incentive Payment System) arm of MACRA. In the MIPS program, providers are required to demonstrate performance in four separate areas: cost, quality, effective use of an electronic medical record, and practice improvement. Providers are scored in each area, and the score is totaled. That composite score determines Medicare fee-schedule changes for each provider in 2019. Performance in each subsequent year then determines the Medicare fee schedule adjustments for 2 years following the performance year. (See table below).

2016 & 2017 Performance Possible Fee Schedules adjusted

+/- 4%
2018 & 2019 Performance/2020 adjustments Fee Schedules adjusted +/- 5%
2021 adjustments Fee Schedules adjusted +/- 7%
2022 adjustments and beyond Fee Schedules adjusted +/- 9%

 

For providers or groups who are not prepared, MIPS could deliver a huge hit to the bottom line. CMS estimates that up to 70% of providers will see a downward adjustment to their fee schedules from MIPS.

In mid-September, Andy Slavitt, the acting CMS administrator, did indeed offer providers a small reprieve by delaying full implementation of MIPS this year and proposing 4 options instead.  This is only for one year, so MACRA and MIPS will be back on the previous timeline with all its implications, beginning in 2018.  For 2017 only, providers may choose one of 4 pathways:

  1. They may choose to report data for the entire year and they would be eligible for a modest fee schedule increase
  2. They may choose to report partial-year data, and would be eligible for small, fee schedule increase
  3. They may choose to submit some quality data and have their performance “shadow” where they might have been in 2017 without the risk of incurring a fee schedule penalty
  4. They could become part of a qualified Alternative Payment Model (APM). This requires being in an ACO that accepts significant risk, such as a Track 2 or Track 3 MSSP ACO. ICP physicians would not be eligible for participation as a Qualified APM. For those ICP physicians participating in the HHC MSSP ACO program, they would qualify as belonging to a partial APM. ACO providers will continue on, as if nothing had changed for the 2017 MIPS implementation.

Again, none of these options affects the implementation timeline in 2018 and beyond, so you really need to be getting ready for MIPS now.

ICP stands ready to help you understand MIPS and MACRA and what you need to do to prepare for this. Feel free to contact your provider services rep, one of our care management coordinators or ICP leadership. Value-based care is here, it likely will have a real impact your practice, and it is not going away.