To Demystify MACRA, Start with Compliance
But we're also telling members not to just do the bare minimum and forget about it, because the program will ramp up over time. We're saying that if you have the capabilities in place and are experienced with previous programs like PQRS and Meaningful Use, you can do quite well under MIPS.
But if you have no experience or you're struggling with those programs, you have an opportunity now to try some new things, look at your EHR, or take other steps to prepare for future success.
HLM: What are your members' biggest pain points—setting up infrastructure, taking risk?
Gilberg: Well, practices aren't forced to take on risk right away, but CMS will have some new advanced alternative payment models (APM) in 2018. We expect the final list of APMs to come out sometime before January 1, 2017.
In the meantime, we're getting a lot of questions about the low-volume threshold, which CMS raised to 100 Medicare patients, or $30,0000 in Medicare revenue. While many single-specialty practices, such as in pediatrics or OB-GYN, will clearly know they're exempted from the rule, it becomes a little more complicated for multispecialty practices.
The rule allows group-practice-level reporting that would mitigate the burden of reporting on every specialty individually and focus on high-impact areas, but these groups are still sorting out what may be the best way to participate.
HLM: CMS did not reduce the lag time between reporting and incentive years as many groups had hoped. Is this still an area of concern?