WHAT YOU NEED TO KNOW TO PREPARE FOR MACRA



WHAT YOU NEED TO KNOW TO PREPARE FOR MACRA The Centers for Medicare and Medicaid Services (CMS) issued proposed regulations this spring outlining agency plans to "align and modernize" Medicare payments in accordance with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Collectively, these changes created the Quality Payment Program, which is divided into two paths that link quality of care to Medicare payments. The path that most hospice and palliative care professionals will utilize, at least initially, is the Merit-based Incentive Payment System (MIPS), which consolidates elements of existing Medicare physician quality and EHR reporting mandates into one new streamlined program, reduces the aggregate level of financial penalties physicians otherwise would have faced, and offers the potential for bonus payments based on high value care. The other path provides incentives for qualifying participants in Advanced Alternative Payment Models (APM) that encourage high-value care. However, since the Advanced APM track requires that entities carry a significant amount of risk and given the fact that the proliferation of APMs to date has been minimal, CMS expects few physicians to qualify for this track in 2017. More detailed information about both of these pathways can be found in this AAHPM summary. Additional resources are available on the CMS Website, including helpful fact sheets and slide sets available here. Although the specific requirements for participating in either of these pathways have not yet been finalized, CMS recently confirmed that this new payment structure will initially be based on physician performance and reporting in 2017 and will first impact Medicare physician payments beginning in 2019. In recognition of the wide diversity of physician practices, CMS intends to allow eligible clinicians to pick their pace of participation in MIPS for 2017 from the following options: Option 1: As long as you submit some data to CMS in 2017, you will avoid a negative payment adjustment. The goal here is to ease clinicians into broader participation in the following two years.Option 2: You can submit data for a reduced number of days, meaning that if your first performance period begins later than January 1, 2017, your practice could still qualify for a small positive payment adjustment. Option 3: Practices that are ready to go in 2017 may submit data for the full calendar year, which would qualify them for a modest positive payment adjustment. With 2017 right around the corner, listed below are some steps you can take to begin to prepare yourself for participation and to assess your overall MACRA readiness. Following this checklist will help ease the transition for your practice, ensure you are engaged in the most meaningful quality improvement activities available, minimize financial penalties, and potentially even help you to earn bonus payments. Please keep in mind that final program requirements and timelines will not be released by CMS until later this fall. AAHPM will continue to keep you informed of new announcements and educational resources as they become available.MACRA ChecklistFamiliarize Yourself with Current Quality Programs: Under MIPS, you will still be required to report quality measure data to CMS, to demonstrate your performance on quality and cost measures, and to demonstrate how your practice is a meaningful user of EHR technology. Therefore, one of the best ways to prepare for MIPS is to participate and assess your performance under CMS’s current quality programs—including the Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VM), and Medicare Electronic Health Record (EHR) Incentive Program (or Meaningful Use). Are you participating in the Physician Quality Reporting System (PQRS) in 2016?Find out which metrics are most important to your system and partners, then build a strategy to ensure you report on these measures. Although available measure sets and reporting thresholds might change slightly in the future, the PQRS will serve as the foundation for the quality portion of MIPS and the overall structure will remain the same. Information about current PQRS reporting options and available measures potentially relevant to hospice and palliative medicine professionals in 2016 is available here. Since registry-based reporting options allow for retrospective year-end reporting, it is not too late to start participating for 2016 if you have not already done so. When assessing your reporting options, consider clinical conditions you usually treat, the type of care you typically provide, and the setting where care is most often provided. You should also consider quality data you might already be submitting for other quality mandates, such as the EHR Incentive Program. Take advantage of 2016 to better incorporate quality data collection into your workflow and to monitor measure performance throughout the year. Make sure that you understand current quality measure reporting requirements and how you are performing since it is anticipated that the fundamental PQRS reporting options will stay the same under MIPS.Keep in mind that additional, potentially more relevant quality measures might be available for reporting in 2017. For example, CMS has proposed to include the following measures under MIPS: proportion of patients receiving chemotherapy in the last 14 days of life; proportion of patients with >1 ED visit in last 30 days of life; proportion of patients admitted to ICU in last 30 days of life; proportion of patients not admitted to hospice; and proportion of patients admitted to hospice for < 3 days. 2. Have you attested to Meaningful Use?Since meaningful use of certified EHR technology (CEHRT) will continue to remain an important element of MIPS, it is important that you adopt CEHRT and satisfy the requirements of the EHR Incentive Program if you have not done so already. Review Meaningful Use requirements for 2016, including this tip sheet, and begin attesting as soon as possible. While most, if not all, of the existing objectives and measures will remain under MIPS, reporting thresholds are expected to be more flexible and lenient. Note that in 2016, the EHR reporting period for all returning participants is a full calendar year (January 1 to December 31, 2016). For first‐time participants in 2016, the EHR reporting period is a minimum of a continuous 90‐day period between January 1 and December 31, 2016. While participation in this program in 2016 will help ensure that you avoid penalties in 2018, new participants in 2016 can also avoid 2017 penalties if they successfully attest by October 1, 2016.Use 2016 as a year to familiarize yourself with the EHR Incentive Program objectives and measures and to incorporate collection of this data into your workflow as much as possible.3. Are you monitoring your performance? The 2015 PQRS feedback reports will depict your program year 2015 PQRS reporting results, including payment adjustment assessments for calendar year 2017. The 2015 Annual Quality and Resource Use Reports (QRURs) will show how groups and solo practitioners performed in 2015 on the quality and cost measures used to calculate the 2017 Value Modifier. Both reports will be available in the early fall, although earlier reports can be accessed in the interim. These reports can help you to better understand your reporting patterns, your overall performance, and to identify opportunities for improvement. The QRURs, in particular, can also help you to identify your most costly patients and identify targeted care delivery plans. Reviewing this information is critical since CMS will continue to evaluate physician resource use based on claims data under MIPS. While the resource use portion of MIPS will not require you to report any extra data to CMS, it is important to understand the metrics that CMS uses to evaluate your resource use and what aspects of care are contributing to your resource use since most of this will not change drastically under MIPS. More information about these reports, including specific instructions on how to secure authorization to access them, is available here. 4. Start thinking about Clinical Practice Improvement Activities. MACRA adds a new component to physician quality assessment whereby clinicians will be evaluated based on their engagement in Clinical Practice Improvement Activities (CPIA). Physicians can maximize their points in the CPIA category of MIPS by participating in specified activities, which are generally intended to advance practice improvement such as care coordination, shared decision-making, safety checklists, and expanded access for patients. Although CMS’s finalized list of activities might differ slightly, it is important to review the proposed rule's list of CPIAs to evaluate what activities your practice is already doing and what adjustments it should make to complete additional activities in 2017.Since the proposed reporting period for CPIAs is 90 days, you should begin to consider which activities would work best for your practice in 2017 under that framework. If you participate in a nationally recognized, accredited patient-centered medical home (PCMH), a Medicaid medical home model, a medical home model, or are recognized by the National Committee for Quality Assurance as a patient-centered specialty model, ensure that your certifications and accreditations (as applicable) are current since participating in these medical homes can earn you full credit in the CPIA category.Consider Your Options for Participating in an Advanced APM in 2017. MACRA allows you to participate in the Quality Payment Program by participating in an Advanced APM. If you are determined to be a qualified participant in an Advanced APM, CMS will refrain from scoring your performance under the MIPS program. Keep in mind that Advanced APMs would have to meet certain requirements such as bearing financial risk for monetary losses, using MIPS-comparable quality measures, and relying on CEHRT. As such, a very limited number of models would currently qualify for this track in 2017. To be considered a qualifying participant and to qualify for potential the 5% Medicare incentive payment offered under the APM track, you also would need to receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced APM in 2017. Since the APM track involves a hefty amount of risk and, as proposed, would rely on steep payment amount/patient count thresholds, CMS expects fewer than 10% of eligible clinicians to qualify for this track in 2017. Nevertheless, there are steps you can take now to prepare yourself for future participation in this track:Take the time to research and understand your local payment and delivery landscape. Meet with leaders in your own system to understand their strategies and learn more about their goals.Confirm whether you are already a participant in any of the following Advanced APMs:Shared Savings Program (Tracks 2 and 3)Next Generation ACO ModelComprehensive ESRD Care (CEC)Comprehensive Primary Care Plus (CPC+)Oncology Care Model (OCM) (two-sided risk track available in 2018)If you do believe you are a participant in any of these models, it is also important to:Verify with the APM administrator that you are included on the APM participant list that they submit to CMS. Evaluate to what extent your Medicare and private payer revenues and the proportion of your patients are associated with these models. Talk with the APM administrator to better understand the entity’s plan for distribution of the Advanced APM incentive payment if they qualify for it in the future. As currently proposed, the APM would receive the incentive payment directly and would then be responsible for distributing it to APM participants so having a voice in this process is important. If you do not already participate in one of these models, identify potential partners outside of your immediate practice to advance more coordinated care plans and innovative payment models.Think strategically about new resources your program may require to close key gaps in care. Present these to your system leaders or partners to encourage their investment in your growth.Continue to invest in CEHRT to communicate clinical care information and to engage in quality measurement since both of these will be foundational requirements of Advanced APMs. However you choose to participate in the Quality Payment Program in 2017, resources will be made available to guide you through your options and walk you through the requirements. We urge you to continue to check the AAHPM and CMS Websites for ongoing updates. ................
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