Last April, President Obama permanently repealed the SGR payment formula by signing the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA, into law. In this guest editorial, international law firm Arnold & Porter LLP offers timely advice for physicians on how to prepare their practices for the implementation of the Merit-based Incentive Pay System (MIPS) and Alternative Payment Models (APM) in 2019. We hope these action items help ready you for the changes in our future as physicians.
– Ira M. Jacobson
Co-Chief Medical Editor, HCV Next
– Michael S. Saag
Co-Chief Medical Editor, HCV Next
Ira M. Jacobson
Michael S. Saag
From international law firm Arnold & Porter LLP comes a timely column that provides views on current regulatory and legislative topics that weigh on the minds of today’s physicians and health care executives.
It’s been nearly a year since Congress enacted the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA, significantly shifting Medicare’s payments to physicians to improve quality and value. The new payment system has two tracks: 1) the Merit-Based Incentive Pay System, or MIPS, and 2) Alternative Payment Models, or APMs. (In case you missed it, background is here.)
MIPS and APM payments start Jan. 1, 2019, based upon the quality and cost of the care you deliver in 2017. CMS is busy with the details of how it will work. What are you doing to get ready?
Jennifer B. Madsen
To “MACRA-mize” your practice, there are some steps you can take now:
Get educated or get help. Medicare payment is policymakers’ primary tool for changing physicians’ behavior. It is increasingly necessary for individual physicians to understand the economics of their practice to inform career planning. Check the websites of your specialty society and the AMA. They’re publishing guides and creating tools and educational events.
Join an APM. A bonus, of 5% of Medicare billing for the year, will be paid in 2019 to “qualifying APM participants” based on services performed in 2017. “Qualifying” requires “meaningful use” of the EHR, reporting quality measures, and having 25% or more of your revenue from risk-bearing APMs.
Explore your options. If you are not in an APM, contact local hospitals and multispecialty practices to see if you can join prior to Jan. 1, 2017.
Report PQRS measures. The Physician Quality Reporting System (PQRS) quality score is 30% of your MIPS composite score. If you have not reported before, start now. PQRS has several reporting options (EHR, registry, etc.); choose one with measures you can report based on your practice.
Review the QRUR. If you’re experienced with PQRS, study your QRUR (Quality and Resource Use Report) to see how the quality and cost measures are combined to determine your quality tier for the Value Modifier, which is 30% of your MIPS composite score.
Be a meaningful user. “Meaningful use” of an EHR counts for 25% of the MIPS composite score. Beginning in 2018, all physicians must meet Stage 3 requirements. Apply to CMS for a hardship exemption prior to March 15 if you are not yet a meaningful user.
Look yourself up on Physician Compare. Public reporting of quality and cost scores on Physician Compare (https://www.medicare.gov/physiciancompare/) is here to stay. CMS will use the Achievable Benchmark of Care (ABC) method to compute quality benchmarks in 2017 and create a five-star rating system on Physician Compare. Understand what data are being used. (It should agree with your QRUR.)
Stay tuned. The MIPS has a new fourth category, Clinical Practice Improvement Activities, which counts for 15% of the MIPS composite score.
Jennifer B. Madsen, MPH, health policy advisor at Arnold & Porter LLP, can be reached at Jennifer.Madsen@aporter.com.