In September 2016—just three months from the release of the final rule of the Centers for Medicare & Medicaid Services (CMS) Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)—half of the physicians surveyed had not heard of MACRA, which establishes a new way to pay doctors for Medicare patients. In January 2017, the beginning of the first performance reporting period, only 19 percent of physicians reported that they were very or somewhat familiar with MACRA.
Physicians and practice managers may feel as if they’re being left at the starting line, but although the first quarter of 2017 is already over, there is still time to get in the MACRA race.
On your mark…
- Assemble a team. A team is vital to tackle MACRA data collection, data analysis, and submission. Team members should come from various roles in the practice. For example, a team might include the practice manager, a physician, a clinical staff member, and an administrative staff member. The team should brainstorm strategies to incorporate metrics into existing workflow and optimize the workflow to include data collection. The team can also then educate the rest of the organization about MACRA and its role in the process.
- Decide whether to report as a group or individual. An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number (TIN). A group is defined as a set of clinicians (identified by their NPIs) sharing a common TIN, regardless of their specialty or practice site. This is also important for the method of submission, because only clinicians reporting as individuals may use a claims submission method and the CMS Web Interface is only available to groups of 25 or more clinicians. Know the criteria, advantages, and disadvantages of reporting in each category—the Quality Payment Program (QPP) website is a helpful resource.
- Pick your pace. In this transitional year of the QPP and alternative payment models, CMS solicited feedback from stakeholders about the burden of reporting under MACRA and responded by making this a learning year. Practices have four options to choose from and can participate as much, or as little, as they choose. It is points-driven: The more participation, the more points earned. The goal is to exceed 70 percent in the composite score to be considered for a bonus. The composite score is composed of Quality + Advancing Care Information + Improvement Activities.
Understand your participation options. For example, most clinicians will report under the Merit-Based Incentive Payment System (MIPS) versus an Alternative Payment Model (APM). There will be a small group of physicians in an APM who will only partially qualify and thus need to report under MIPS. It’s important to understand this and report correctly to avoid a negative adjustment.
- Select measures and submission methods. Choose measures that best fit your practice. Understand that not all of the measures are equal in value. Under the quality category, one measure could earn as many as 10 points. Take time to review your options.
The measures may be reported in several ways, including through the electronic health record (EHR), a qualified registry, CMS Web Interface, and administrative claims data. Submission methods are particularly important because they will increase points, which affects the composite score and may assist in maximizing payment or earning a bonus.
The EHR is one of the easiest ways to capture and report data. Consult your EHR vendor about functionality and creating a workflow for collecting data and reporting. EHR vendors are the primary source for ensuring the documentation of best practices data is accurately captured in the software and producing correct credits for the work provided.
Regardless of how reporting is done, now is the time to work out the process and learn how easy or difficult it is to upload and track progress prior to final submission. At least 90 consecutive days of data is required to be considered for a positive upward or neutral adjustment.
- Review and improve. Evaluate past performance in the Physician Quality Reporting System (PQRS), which now becomes the Quality Measures and will have the greatest weight (60 percent of the composite score).
Review past performance in the Meaningful Use (MU) measures. MU now becomes Advancing Care Information (ACI) and will require greater participation than in the past. Prior to 2017, measures had low thresholds and were easy to attain. As of 2017, it’s necessary to include as many patients as possible. Practices will also have base measures to report, including conducting or reviewing a security risk analysis; e-prescribing; and providing patients with access to view, download, and transmit their health information.
A new performance category for 2017 is the Improvement Activities (IA). Most groups will attest to completing four activities. Small groups with less than 15 physicians will attest to two activities. These activities focus on patient safety, care coordination, and engagement.
- Start now. Reporting a single measure will avoid a negative adjustment in 2019. Don’t stop there—take advantage of this transition year. Don’t aim for the bare minimum. Instead, use this time to learn as much as possible and close as many gaps before the year’s end. This time is designed for practices to implement workflows and processes to be successful for 2018 and beyond.
Use this time to partner with your EHR vendor. Don’t wait until the third or fourth quarter to find out data is not calculating. Schedule weekly calls with your EHR account manager. Ask for a user guide, provide it to your team, and review it often to close gaps in documentation.
If you are already reporting PQRS and MU, you’re halfway there. If you’re not reporting yet, there is still time to start before October 2, 2017—and the earlier the better. The positive or neutral adjustments are less challenging to meet in 2017, and what is done this year will reflect in the 2019 public reporting and pay-for-performance. Delaying participation may make next year more challenging.
For more information, go to the Medical Advantage Group website or contact The Doctors Company Patient Safety Department at email@example.com.