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The MACRA Final Rule allows flexibility in implementing MACRA for Medicare. Physicians can choose MIPS for Quality Payment Program, or APM.

MACRA Implementation: Pick Your Pace

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One of the most positive features of the MACRA Final Rule is that physicians have a degree of flexibility in implementation.

You can start collecting your performance data any time between January 1 and October 2, 2017. Whenever you choose to start, you’ll need to send in your performance data by March 31, 2018. The first payment adjustments based on performance go into effect on January 1, 2019.

If you choose the MIPS track of the Quality Payment Program, you have three options:

  1. Submit something: If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity), you can avoid a downward payment adjustment.
  2. Submit a partial year: If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.
  3. Submit a full year: If you submit a full year of 2017 data to Medicare, you may earn a moderate positive payment adjustment.

Note that if you don’t send in any 2017 data, you will receive a negative 4 percent payment adjustment.

If you choose the Advanced APM track, you can earn a 5 percent Medicare incentive payment in 2019 when you receive 25 percent of Medicare covered professional services or see 20 percent of your Medicare patients through an Advanced APM in 2017.

For providers participating in either MIPS or an Advanced APM, the cycle of the program works like this for the 2019 payment year:

2017: Measure performance. Record quality data and how you used technology to support your practice. If an Advanced APM fits your practice, provide care through that model during the year.

March 31, 2018: Send in performance data. To potentially earn a positive payment adjustment under MIPS, send in data about the care you provided and how your practice used technology in 2017 by the 2018 deadline. In order to earn the incentive payment for participating in an Advanced APM, send quality data through your Advanced APM.

Interim: Medicare provides feedback. Medicare will provide feedback about your performance after you send your data.

January 1, 2019: Payment Adjustment. You may earn a positive MIPS payment adjustment or an Advanced APM incentive payment.

Source: Centers for Medicare and Medicaid Services.


Healthcare Practice Strategies - Winter 2017

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