MACRA‚ first year: A Look at reporting requirements, challenges, and what may be next

On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) released its 2018 final rule, reflecting updates and changes to the Medicare Access and CHIP Reauthorization Act’s (MACRA) Quality Payment Program (QPP). The 2018 rule, which implements changes to the two pathways for clinicians participating in Medicare fee-for-service: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs), can be seen in many ways as a response to concerns raised since the QPP was first announced regarding resource and workflow burden, as well as the overall complexity of the elements to successfully report.

How we got here

As the end of the QPP’s first year rapidly approaches, CMS has maintained flexibilities from the 2017 transition year in an effort to help clinicians prepare for 2019, when full implementation of the rule takes hold. And with the first reporting submission deadline of March 1, 2018, for MIPS participation nearing quickly, it is evident that such flexibility is warranted, as eligible providers across the care continuum remain at varying levels of readiness for this new era of physician payment. Part of that variability likely stems from providers feeling overwhelmed with MIPS requirements. According to the Medical Group Management Association’s 2017 Regulatory Burden Survey, the QPP topped respondents’ list of issues they see as “very” or “extremely” burdensome. In addition, more than 70 percent of group practices said they view the MIPS scoring system as “very” or “extremely” complex.

Concerns about the resource and workflow burden, as well as the complexity of MACRA, have not gone unnoticed. On October 30, 2017, just days prior to release of the 2018 final rule, CMS Administrator Seema Verma addressed a series of efforts the agency has underway to streamline quality measures, reduce regulatory burden and promote innovation across the healthcare landscape. In addition to highlighting CMS’ work to implement the QPP in a way that minimizes the burden and costs providers face in meeting the requirements, Administrator Verma unveiled the agency’s new “Meaningful Measures” initiative, which will focus on the use of outcomes-based measures to assess those core issues that are most vital to providing high-quality care and improving patient outcomes.

What’s next?

Industry stakeholder response to the 2018 final rule has been largely positive, with many voicing strong support for CMS’ decision to maintain the transitional nature of the program for 2018. CMS is continuing to transition slowly and offering new incentives for participation.

For instance, the 2018 final rule continues the “pick your pace” option under the Merit-Based Incentive Payment System (MIPS), which was established in the QPP implementation policy for 2017 and allows clinicians to choose their level of participation in the program, granting some additional breathing room to those still struggling to meet the QPP requirements.

The final QPP rule also eases the burden for small practices, exempting physicians from MIPS participation if they have less than or equal to $90,000 in Part B allowed charged or see fewer than 200 Part B patients for 2018. As a result of this change, only 40% of all clinicians who bill Medicare will be subject to MIPS participation. In addition, solo practitioners and small practices will have the ability to form or join virtual groups so that they have a better chance of meeting eligibility requirements for the MIPS bonus.

Of concern to many physicians following finalization of the 2017 QPP rule was the policy that physicians would be required to use only the 2015 edition of Certified EHR Technology (CEHRT), despite the fact few electronic health record vendors meet the 2015 CEHRT criteria. The final 2018 QPP rule continues to allow physicians participating in MIPS to use either the 2014 or 2015 CEHRT for 2018.

The agency has also made it easier for clinicians to participate in select Advanced Alternative Payment Models (advanced APMs), including extending the 8% “risk standard” through performance year 2020 and making it easier for clinicians to qualify for incentives for participation in APMs that begin or end in the middle of the year.

Data-driven analytics support QPP reporting requirements

Managing and improving patient outcomes while maintaining cost efficiencies is no small feat. Providers’ understanding of and readiness to operate within QPP requirements is paramount to successful implementation of value-based care. Moreover, if you are a healthcare provider required to report under the QPP, your current performance will absolutely impact your future payment adjustments. Accurate clinical documentation will be essential to success under MIPS.

Data-driven analytics can support quality reporting requirements under the QPP by offering actionable insights into expected performance and improvement opportunities, as well as helping identify and evaluate the impact of improving performance on key measures to inform goals. For instance, “data silos”—common in provider organizations—prevent physicians from receiving comprehensive data on patient outcomes, impacting overall quality performance. But sophisticated data visualization and reporting capabilities can offer a “single source of truth” into the compilation of all the disparate data—quality measures, utilization trends, gap assessments and enrollment data—you need to drive improvements in quality measurement, reporting and overall health outcomes to succeed in this program.

The ability to assess the impact of measure-level changes in performance and influence strategy in real time, enabled by relevant and focused data-driven insights, is what will truly set healthcare organizations apart and ensure QPP readiness and success in the constantly evolving healthcare landscape.

For more on how Inovalon can help your organization adjust to impactful industry shifts like MACRA, contact our team.

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