MACRA final rule overview

The Kentucky REC team is busily dissecting the MACRA Final Rule for Kentucky providers. We will be providing an analysis and holding a webinar for providers soon. Make sure to sign up for our regional seminars in the coming weeks – we’ll have a user friendly overview of MACRA at those events.

In the meantime, here’s our summary of the major changes to the new Quality Payment Program:

Pick your pace. Providers now have five options in year one with graduated rewards or penalties:

  1. Don’t participate (subject to the full four percent penalty in Medicare payments in 2019).
  2. Send some data for at least one measure (no penalty, no bonus).
  3. Send partial data for a 90-day reporting (more than one measure) (no penalty, some bonus possible).
  4. Participate fully for a full year (no penalty, larger bonus possible).
  5. Participate in an Alternative Payment Model (no penalty, even larger bonus possible).

Quality counts. Quality is now 60 percent of the composite performance score and resource use is reduced to zero percent for the first year. Other category scoring is unchanged. Individual clinicians and groups report six quality measures (if participating in the full year option). CMS clarified that groups using the CMS web interface need to submit the 15 quality measures CMS has selected for a full year.

It’s easier to NOT qualify. An “Eligible Clinician” is still a physician, a physician assistant, a nurse practitioner, a clinical nurse specialist or a certified registered nurse anesthetist participating in Medicare. However, the low volume threshold has been adjusted in the final rule. So, among these providers, those who do not bill at least $30,000 a year under the Medicare Physician Fee Schedule or provide care for more than 100 Medicare patients a year are exempt. First year Medicare participating clinicians are also exempt.

The grading curve has changed substantially. CMS has stated that in 2017 the performance threshold will be lowered to three points out of 100 for not receiving a penalty. Still want to be an overachiever? You can do more than the minimum and potentially qualify for larger bonuses. Clinicians who achieve a final score of 70 or higher will be eligible to split an exceptional performance pool of $500 million.

A rose by another name still has thorns. Advancing Care Information requirements (which is the new name for what was formerly Medicare Meaningful use) were reduced to just five required measures:

  1. Perform an annual Security Risk Assessment.
  2. Use e-prescribing.
  3. Ensure Patient Access.
  4. Exchange Summary of Care information.
  5. Request or Accept Summary of Care information.

But you can also submit up to nine measures for 90 days for additional credit. We are reviewing the health information exchange requirements and still think these will be a sticking point (pun intended).

Improvement Activities – the name and the requirements are shorter. Requirements were reduced from six down to just two to four activities for at least 90 days. Providers in rural or health professional shortage areas and non-patient facing providers must only do one to two improvement activities. Certified medical home practices can get full credit automatically in this category, as do APM participants eligible for special scoring (e.g., Track one and Oncology Model participants). Other APM participants get at least half credit under this category. If using PCMH certification for this category, at least one practice for the group must be certified with a medical home organization that meets CMS outlined criteria.

New Advanced APM options coming soon! Beginning in 2018, MSSP ACO Track 1+, the Cardiac and Joint Care Episode Payment Model and a new voluntary bundle option will also be eligible for five percent advanced APM bonus. As previously specified in the proposed rule, participants in 2017 for the following options of CPC+, ESRD Model, MSSP Track two and three, and Next Generation ACO could qualify for the five percent advanced APM bonus in 2019.

We know, we know – all these new words and acronyms sometimes sound like Greek to us, too. Hang in there – help is on the way. The Kentucky REC team is working on a user-friendly translation of the 2300+ page final rule. Stay tuned for more!

-UK HealthCare’s Kentucky Regional Extension Center