Two weeks after CMS released the final rule, medical groups continue to sort out what this massive payment change means to them.
MACRA may not hold the same mystery it did earlier this year, now that the Centers for Medicare & Medicaid Services has released nearly 2,400 pages of details in its final rule, but practices are still clamoring for information, says Anders Gilberg, senior vice president of government affairs for the Medical Group Management Association (MGMA).
For its 2016 annual conference, held earlier this week in San Francisco, MGMA created a track of concurrent sessions titled "Under the MACRAscope." All of the sessions had been filled to fire-regulation capacity on Tuesday, when Gilberg answered a few questions. The following transcript has been edited.
HealthLeaders Media: What are you hearing from MGMA members now that the final rule has dropped? Is there a sense of relief? Anxiety?
Gilberg: The rule alleviated the immediate pressure that would have otherwise occurred if CMS finalized its proposed rule, which would have been like flipping a switch on January 1 to a whole new program.
There's a huge improvement in the final rule, at least for 2017. CMS significantly lowered the bar to avoid a penalty in 2017. All you have to do is send in one quality measure for one patient one time in 2017 and you will not get the 4% Merit-Based Payment Incentive System (MIPS) penalty in 2019.
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?
Gilberg: If there's any area where the rule misses the mark completely, I think it's that—the difference between the performance year and the incentive year that the fact that physicians won't receive a feedback report until August 2018 on care they delivered as early as January 1, 2017.
Our members will be quick to tell you that information is not actionable for quality improvement purposes. It's just a retrospective report card.
If CMS really wants this to be a quality program, it will have to provide real-time data that practices can use in time to intervene. The need to catch gaps in quality and cost along the way is at the root of why the industry is moving toward value based care.
But the feedback loop is so disconnected right now that most people are just trying to figure out how to comply with the rules.
Debra Shute is the Senior Physicians Editor for HealthLeaders Media.