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MACRA changes our health care system from fee-for-service for Medicare patients - CMS, through PQRS, requires performance data through MIPS or APM.

MACRA: The Long Awaited Final Rule is Out

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was enacted in April 2015. MACRA repealed the dreaded Medicare Sustainable Growth Rate (SGR) and replaced it with a new payment approach known as the Quality Payment Program (QPP). CMS has made its position clear with this legislation; our health care system will be moving away from a fee-for-service world and transitioning to payment models that reward quality outcomes and lowering of costs. As we have discussed in previous posts, most practitioners will fall under the Merit-Based Incentive System (MIPS) and a much smaller number will qualify for payments under the Advanced Alternative Payment Models (APMS).

During the comment period, CMS reviewed more than 4,000 comments with over 100,000 participants in the various outreach sessions. The final rule is massive in volume with almost 2,400 pages of information, although much of it is feedback. The feedback received by CMS during the period of comment can be distilled down to a basic request for simplicity and flexibility.

The final rule does in fact attempt to ease the pressure on providers by making 2017 a transition year. Providers can “pick their own pace” in terms of the level of participation. Unless exempt, providers will need to collect information anytime from between January 1, 2017 and October 2, 2017. Providers will only need to provide a minimum amount of data to CMS in order to avoid the 4% negative payment adjustment in 2019. Providers do have the option of providing more than the minimum amount of data in order to receive a positive payment adjustment. Performance data will be due by March 31, 2018. Additionally, a physician can participate in an Advanced APM (which involves more risk) and potentially earn a 5% incentive payment in 2019.

Here are some of the other important changes in the final rule:

  1. There has been an increase in the low volume threshold from $10,000 to $30,000. In other words, if a physician has less than or equal to $30,000 of Medicare Part B charges or less than or equal to 100 Medicare patients, he/she is exempt from the initial year reporting. 
  2.  For the 2017 reporting year of MIPS, providers will not be evaluated on the cost or resource component. This component replaces the value-based modifier.
  3. Quality measure benchmarks will be published in 2017. In the final rule, CMS indicates that it will finalize the benchmarks (based on PQRS data) and publish them in advance of the performance period.
  4. In order to further assist smaller practices, CMS has provided for “virtual groups” as a reporting option. However, the virtual groups will not be implemented during 2017.

Comments will be taken by CMS on the final rule for 60 days, commencing October 14 of this year. This is a transitive period and CMS is looking for this program to be successful on a long-term basis.

CMS has launched a website with an explanation of MACRA.

Curt Rosner is a Partner serving as a tax and business advisor to professional firms, businesses and entrepreneurial individuals, with significant experience in complex tax planning and assisting businesses with strategic planning.

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