Federal Health Law Alert – Macra Final Rule

Thursday, October 17, 2019

Centers for Medicare and Medicaid Services (CMS) released final rule and comment period on MACRA bringing of the greatest change since the enactment of the Accountable Care Act in 2010.  MACRA or the The Medicare Access and CHIP Reauthorization Act of 2015 will further efforts to incorporate quality measures into payments for physicians and clinicians with new policies that go into affect as early as January 1, 2017.  These new policies will address options for participation of payment models that will effect eligible physicians and other clinicians that have more than $30,000 in Medicare Part B  allowed charges or more than 100 Medicare Patients annually.

MACRA will change current modes of  Medicare reimbursements into one program referred to as the Quality Payment Program which includes two tracks eligible physicians and clinicians can participate in either Advanced Payment Models or the Merit-based Incentive Payment System.  According to the MACRA Final rule the Quality Payment Program aims to fulfill three objectives while it repeals the Medicare sustainable growth rate (SGR); (1) support care improvement by focusing on better outcomes for patients, decreased provider burden, and preservation of independent clinical practice; (2) promote adoption of alternative payment models that align incentives across healthcare stakeholders; and (3) advance existing efforts of Delivery System Reform, including ensuring a smooth transition to a new system that promotes high–quality efficient care through unification of CMS legacy programs.

The  Quality Payment Model  will “reward value and outcomes in one of two ways”

  1. Advanced Payment Models (Advanced APMS)

This program will reward clinicians that provide efficient and coordinated care with the ability to receive a five percent incentive bonus in participation of this program. List of APMS will be  finalized before January 1 ,2017 with requirements for eligible clinicians to become qualified as “QP”or Qualified APM Participants.

  1. Merit-based Incentive Payment System (MIPS)

The MIPS  program will consolidate three existing programs: The Physician Quality Reporting System, the Physician Value- Based Payment Modifier, and the Medicare Electronic Health Record Incentive Program. The MIPS program will be based on four “pillars” of measure: 1) quality 2)clinical practice  improvement activities 3) meaningful use of CEHRT or advancing care information and 4)resource use referred to as cost to create a composite score. The score will determine adjustments made either positive or negative from data gathered in CY 2017 to reimbursements for CY2019.

During CY 2017 where CMS termed as a  transitional year,  CMS will provide “pick your pace” options for submission of amount of data and time periods that will affect physician and clinician reimbursements in CY 2019. Momentum Consulting Group’s Healthcare Consultants are analyzing and mastering one of the most significant changes affecting all entities in the healthcare field. Our research teams and Consultants will be able to create strategies best suited for the physicians needs while providing tailored education and insight on which path physicians can continue to excel.