With the clock ticking on the proposed Jan. 1, 2017 start date for the Quality Payment Program created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the field breathed a collective sigh of relief when the Centers for Medicare & Medicaid Services (CMS) announced that it will provide clinicians with flexible options to satisfy reporting requirements in 2017.
The AHA had urged CMS to provide clinicians with flexibility to meet the aggressive timelines and reporting requirements of the program, and we were pleased that CMS has signaled it will provide exactly that. Specifically, CMS said it will allow clinicians to “pick their pace” by selecting one of the following three options under the new Merit-based Incentive Payment System (MIPS) track:
- Clinicians who report “some data” in 2017 will avoid payment penalties in 2019.
- Clinicians who report less than a full year of data may be eligible for a small bonus payment in 2019.
- Clinicians who report a full calendar year of data may be eligible for a “modest” bonus payment in 2019.
Although CMS’s announcement assures clinicians that they may have additional time to prepare for full MIPS participation without incurring penalties, it also introduces an element of uncertainty. CMS’s announcement included few details about how the new options will be implemented, and those details will not be available until CMS releases its final MACRA rule sometime in the next few weeks. This means that clinicians will have just two months to evaluate and select an option before Jan. 1.
To assist hospitals and their clinician partners with navigating this uncertainty as they prepare for the start of the program, we have created a MACRA Tracker that catalogues the “known knowns,” the “known unknowns,” and the “unknown unknowns.” This tool will help hospitals evaluate where to invest time and resources in preparing for the program by identifying the areas where we can predict with some certainty what the final program will look like, the areas where we expect some changes in the final rule (“proceed with caution”) and the areas where we expect to see major changes.
Over the next few weeks, we will roll out additional tools to assist with MACRA implementation and education, including an educational video series and a tool with strategic considerations and issues as hospitals and clinicians assess their preparedness for MIPS. Once the final rule is released, we will provide a detailed analysis of its provisions and their implications. Finally, we are developing a toolkit that will provide a deeper dive into many aspects of the new program, including quality reporting requirements and partnering with clinicians to promote value-based care.
Stay tuned for more – there will be a lot to learn about the MACRA in the next few months, and the AHA stands ready to help.