CMS Offers Four Options for MACRA Compliance in 2017
Thursday, September 8, 2016
Posted by: Bradley Coffey, MA, AAOE Government Affairs
Baltimore, MD - The Centers for Medicare and Medicaid Services (CMS) today announced that providers would have four options for complying with the new MIPS program in 2017. In a blog post, CMS Acting Administrator Andy Slavitt, MBA announced that providers would be given four options for compliance with the program that was implemented under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
Under the first option, providers would be permitted to report only some data after January 1, 2017 in order to avoid a negative payment adjustment. This option, Slavitt says, is for providers to determine that their systems are working and that they are prepared for full participation in 2018 and 2019.
Under the second option, providers could choose to submit data for a reduced number of days. Under the proposed rule, providers were to report data for a full calendar year (January 1, 2017 - December 31, 2017). This option would allow providers to receive a small positive payment adjustment.
Under the third option, providers may submit for a full calendar year and receive a "modest positive payment adjustment". Slavitt estimates that physician practices of all sizes will be able to successfully submit a full year's quality data by January 1, 2017.
Under the fourth option, providers may participate in an Advanced Alternative Payment Model (A-APM)such as the Medicare Shared Savings Program Tracks 2 or 3. Providers caring for enough patients through an A-APM would qualify for a 5% incentive payment in 2019.
It is worth noting that options three and four were already proposed in the Notice of Proposed Rulemaking released in April 2016. Healthcare groups, including the AAOE, have provided feedback to CMS on the agency's proposals. One of AAOE's issues of focus in its comments was the short time between release of the final rule (November 1, 2016) and the start of the demonstration period (January 1, 2017). In AAOE's comments on the proposed rule, AAOE President Jan Vest, MBA wrote:
We urge CMS to allow for a continuous 90-day reporting period in 2017 to allow, physicians, administrators, and patients time to adjust to various requirements of the new program. Our concern is that without a transition period, MIPS eligible clinicians may opt-out of MIPS and Medicare altogether and thus defeat the purpose of MACRA, which is to support high quality, value based care for Medicare beneficiaries using certified EHR technology.
It should be noted that Slavitt assures providers in his post that choosing one of these options will exempt providers from a negative payment adjustment in 2019, the first year that providers will be penalized under the new program for poor performance. It is likely that CMS would apply a negative payment adjustment to providers choosing not to participate in one of these options in 2017.
You can use AAOE resources to help you prepare for MIPS. Visit AAOE.NET/forums to discuss the program with your colleagues (you must first log-in to your AAOE account to access the forums) and visit AAOE.NET/mips to learn more about the requirements.
Please contact AAOE's Government Affairs Manager Bradley Coffey, MA with any questions regarding the MIPS program and other legislative and regulatory matters at firstname.lastname@example.org or 317-749-0629.