Nathan, Healthcare IT team By Nathan Stott, Practice Director

If you haven’t yet settled down to read through the 2,398-page tome that is the MACRA Final Rule published by CMS on October 14, 2016, no need to worry. We read it and outlined the most important changes for you to be aware of for 2017.

The proposed rule, first announced in April 2016, received more than 4,000 public comments. One of the most important issues the final rule addressed was the ‘Pick Your Pace Provision’ which allows flexibility in how clinicians can participate in the Quality Payment Program in 2017. There are four options:

  • Test – Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize their chances to qualify for a positive adjustment. In addition, exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
  • Full Participation – Clinicians can choose to report to MIPS for a period of time less than the full year (2017), but greater than 90 days. Clinicians that choose this path must report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category.
  • Partial Participation – Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category. Alternatively, if MIPS eligible clinicians choose to not report any measures or activity, they will receive the full negative 4% adjustment.
  • Advanced APMs – If a clinician receives a sufficient portion of their Medicare payments, or sees a sufficient portion of their Medicare patients through the Advanced APM, they will qualify for a 5 percent bonus incentive payment in 2019.

The next issue addressed by the final rule was how the first reporting period(2017) will affect physician payments in the first payment period(2019). Participation and measure selection across the four MIPS performance categories will be as follows for the transitional year of 2017.

  • Cost0% of 2017 performance score: The weighting of the Cost performance category has been lowered to 0 percent for the transition year. No reporting will be required by clinicians. Weighting in performance year 2 will increase to 10% of total score.
  • Quality10% of 2017 performance score: For full participation in the Quality performance category, clinicians will report on six quality measures, or one specialty-specific, or subspecialty-specific measure set.
  • Advancing Care Information 25% of 2017 performance score: For full participation in the Advancing Care Information performance category, MIPS eligible clinicians will report on five required measures.
  • Improvement Activities 15% of 2017 performance score: For full participation in the Improvement Activities performance category, clinicians can engage in up to four activities, rather than the proposed six activities.

Between approximately 592,000 and 642,000 eligible clinicians will be required to participate in MIPS in its transition year. Assuming that 90 percent of eligible clinicians of all practice sizes participate in the program, it is estimated that MIPS payment adjustments will be equally distributed between negative MIPS payment adjustments ($199 million) and positive MIPS payment adjustments ($199 million). Positive MIPS payment adjustments will also include an additional $500 million for exceptional performance (eligible clinicians whose performance meets or exceeds a threshold final score of 70).

2017 will be a crucial year for clinicians hoping to receive a neutral or positive payment adjustment in 2019. Choosing which path to take in the transitional year, as well as employing strategic measure selection will be pivotal in not only garnering maximum incentives but in securing future success under MACRA.

About Nathan // After earning a degree in Business Administration from Rutgers University, Nathan has been exclusively providing consulting services within the IT and Healthcare industry. As our Practice Director, Nathan develops all of our Health IT strategies and oversees our clients’ continued success by ensuring ongoing regulatory compliance, EHR optimization, and clinical workflow efficiencies.