The final rule on the massive physician payment overhaul law came out on Oct. 14. Since then, interest and advocacy groups have been combing through the 2,400-page regulation and further clarifications are trickling out.
As a refresher, the Medicare and CHIP Reauthorization Act of 2015 (MACRA) aims to replace years of uncertainty around Medicare payments to physicians. It also revises requirements for health IT adoption and provides incentives for physicians to move towards value-based payments.
That’s a lot of change. We could spend hours talking about MACRA.
Briefly, there are two pathways for physicians to choose: Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). The umbrella program for both is now called the Quality Payment Program (QPP).
Most physicians will fall under MIPS. Only about 10 percent of clinicians are expected to qualify as APMs in 2017. Here’s a quick summary of what journalists should know now about the final rule. These six items apply to the MIPS pathway, which most physicians will follow. I’ll write more about APMs in a separate post.
- Penalties. If qualified providers don’t participate in 2017 or get an exemption, they will face a 4-percent penalty in 2019.
- Required reporting. To participate in 2017, physicians only need to report one quality measure for one patient, or the quality improvement or electronic health record requirements. Just reporting something allows physicians to avoid a 4-percent penalty.
- There now is a “pick your pace“ option for clinicians to ease them into the MIPS program.
- Scoring. Here are the criteria:
- Quality Activities (60 percent of score). This has a total of six measures. As stated above, in 2017, physicians only need to report one in 2017.
- Clinical Improvement (15 percent of score). This has either four or two activities, down from six total in the proposed rule.
- Advancing Care Information Performance (25 percent of score). This is the health IT portion that replaces Meaningful Use – clinicians must report five EHR-use measures, down from a proposed 11.
- Cost (currently zero percent of score). There’s no cost component to 2017, though interest groups for physicians said they would be monitoring a possible cost addition for 2018.
- Reporting. Physicians under MIPS only need to report on a minimum of 90 continuous days, instead of a previously proposed full year.
- There’s a low-volume threshold for participation. Physicians with less than $30,000 in Medicare Part B revenue or 100 or fewer Medicare patients are exempt. Also exempt are physicians who are only in their first year of providing care for Medicare patients.
The final rule has a 60-day comment period. In a future post, I’ll go into more detail on how the final rule affects health IT and the formation of “virtual groups” expected to come in 2018.