CMS emphasizes flexibility in webinar on proposed MACRA rule

The new reporting system proposed by CMS to implement 2015’s Medicare Access and CHIP Reauthorization Act (MACRA) is designed to simplify its measurements while eliminating redundancy and overlap, the agency emphasized in a May 3 webinar.

Delving deeper into the changes in the proposed regulation, CMS officials went over the numerous criteria factoring into the two new reporting paths—the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs)—along with how and when clinicians would be scored under the new system.

Most Medicare physicians will participate in MIPS, with payments linked to four measurement criteria: quality, cost, clinical improvement and technology use, now called “advancing care information." The quality category would be weighted to account for 50 percent of the MIPS score in the first year of the program, while the number of measures determining a clinician’s quality score would be reduced to six.

“Clinicians have the ability to select those six measures, either from our extensive list from measures that are available—there are close to 300 measures—or, one of the things that we have heard through our engagement and speaking with clinicians throughout the country is that it’s much easier to determine which measures are applicable to you based on your specialty,” said Molly MacHarris, program lead for MIPS at the Center for Clinical Standards and Quality at CMS. “So in order to reduce burden, we have created and proposed specialty member sets, which should really help clinicians in identifying which measures would be applicable to them.”

The other half of the MIPS score will be divided between advancing care information (25 percent), practice improvement (15 percent) and resource use (10 percent). MacHarris said measures and activities will be converted into points within each of the four weighted categories, and clinicians will know in advance what they’ll be measured against, promising to “publish measurement bookmarks in the MIPS performance threshold prior to the beginning of the performance period.”

Flexibility with new measures was also emphasized when the advanced APMs pathway was discussed.

“There is no single mold for a particular APM,” said James Sharp, JD, MPH, MACRA lead for the CMS Innovation Center. “So we want to continue to allow that broad flexibility on what APMs are pursuing so that we can see these as the future of how we pay for care under Medicare.”

To qualify as an advanced APM, and thus be exempt from MIPS requirement, organizations will have to meet three criteria: requiring participants to use certified EHR technology, basing payments on quality measures similar to MIPS and bearing “more than a nominal financial risk” for losses, unless the organization falls under the Medical Home model.

APMs would receive an added incentive: a 5 percent lump sum bonus between 2019 and 2024 based on the payment for services the year before.

The timelines for implementing the two pathways are similar. The first performance period for MIPS and APMs would be the calendar year 2017. For MIPS, there would be feedback reports in July 2017 and 2018, with MIPS adjustments taking effect in 2019. Adjustments would be capped at either positive or negative 4 percent for 2019, with the maximum increasing each year until it hits 9 percent in 2022.

For APMs, 2017 would determine if organizations qualify for this pathway instead of MIPS. 2018 would provide the base period for the lump sum incentive, which would be paid out in 2019.  

For smaller practices trying to get prepared for either pathway, the MACRA legislation will allocate $20 million annually between 2016 and 2020 to “provide technical assistance regarding MIPS performance criteria or transitioning to an APM.”