MACRA: Flexible But Still a Reality

After much physician feedback and criticism since they announced the proposed rule for the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), The Centers for Medicare & Medicaid Services (CMS) announced last week that it will allow providers to choose the level and pace at which they comply with the new rule, which will transition healthcare from fee-for-service to fee-for-value beginning on January 1, 2017. This flexibility will come in the form of three different reporting options for MIPS in order to help practices transition to the new Quality Payment Program.

These three reporting options for MIPS are as follows:

  1. Full-year reporting, beginning January 1, 2017 – Practices who are ready to go on January 1, 2017 may want to choose this option for the potential of a “moderate” positive payment adjustment.
  2. Partial year reporting – Submit information for a reduced number of days. You may begin your first performance period later than January 1, 2017 for a possible “small” positive payment adjustment
  3. Test submission by reporting a minimal number of data elements – Avoid a negative payment adjustment by submitting some data in order to ensure that your system is working and that you are preparing for broader participation in coming years.

To note:

  • Opting for full-year reporting will make you eligible for a “modest” increase
  • Opting for partial-year reporting may earn you a “small” increase
  • The test submission option will not earn you an increase, but you will not receive a penalty, either
  • Organizations who choose to report nothing will experience a -4% penalty
  • The Advanced APM track remains available and has not been impacted
  • Providers should prepare for MACRA by continuing to report through existing programs

Andy Slavitt also announced that CMS will release the final rule by November 1, 2016. Our goal is to provide you with the tools to find success in this transition, as we did through Meaningful Use and ICD-10 implementation.



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