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CMS Reveals Proposed Rule updates for MACRA 2018:  More Flexibility, Improvements & Updates On The Way

We are now halfway through 2017, MACRA’s Transition Year, that allowed you to “pick your pace.” The Centers for Medicare & Medicaid Services (CMS) gathered data over the past six months and has proposed a new rule for 2018. They are calling the  MACRA 2018 program, “The Quality Payment Program Year 2”.  You have until August 21st to respond with any comments on the proposed 2018 rule.

macra-2018-optimum-healthcare-itMACRA 2018 – What isn’t changing

CMS’s Quality Payment Program (QPP) goals for MACRA haven’t changed:

  • Improve health outcomes
  • Spend wisely
  • Minimize burden of participation
  • Be fair and transparent

QPP significantly changes the way clinicians are paid through Medicare. CMS knew real and meaningful participation is key to meaningful measurement and improving patient outcomes. They also knew that they need to continue to make it easier for clinicians to participate.

The 2017 Transition Year eased the process for clinicians in three ways. The ability to pick their pace of MIPS participation allowed clinicians to decide how much, and how fast to dive into MIPS.  Exemptions were provided to those who had a low-volume of Medicare Part B patients. Flexible options were offered to clinicians who have limited patient-facing encounters.

Good News: Expect more flexibility in MACRA 2018

CMS now has data from the first half of 2017 and found that the gradual implementation process is working.  They are keeping the momentum going by only modestly increasing performance period requirements, as well as a few other proposals:

  • Virtual Groups participation – Your virtual group members don’t need to share the same physical location
  • Increasing the low-volume threshold – which would exempt more clinicians in rural and Health Professional Shortage Areas
  • Increase bonus points for caring for complex patients, and using the 2015 Edition of the Certified Electronic Health Record Technology (CEHRT) exclusively.
  • Incorporating both MIPS performance improvement in scoring quality performance and the option to use facility-based scoring for facility-based clinicians.
  • A new hardship exception for clinicians in small practices for the Advancing Care Information performance category

New Improvement Activity & Exceptions

The Appropriate Use Criteria (AUC) was begun in 2016 and continues into 2018.  CMS proposes adding a new improvement activity.  MIPS eligible clinicians can choose this activity, if they attest they are using AUC, and meet the decision-making standards for all advanced diagnostic imaging services.

The 21st Century Cures Act affects how CEHRTS affect the QPP, both during the transition year and in future years.  For part of 2017, and into 2018, there are two notable provisions – both affect the Advancing Care Information performance category.  First, ambulatory surgical center (ASC)-based MIPS eligible clinicians will have their category score reweighted to 0%.  Second, CMS will provide significant hardship exceptions.

APM Changes & Updates

APMs are mostly staying the same with the exceptions of a few changes and updates.  Four of the changes and updates they call out are:

  • Extending the revenue-based nominal amount standard for 2 more years, that allows an APM to meet certain criterion to qualify as an Advanced APM if participants bear total risk of at least 8% of Medicare A & B revenue
  • Increases total risk more slowly for Medical Home Models
  • Provides more info on the All-Payer Combination Option that begins in 2019
  • Provides more info on how MIPS APMs will be scored under the APM standards

You can check out the fact sheet for more details, and a comparison of current and proposed policies.

Got something to say about Year 2?

Check out the first three pages of the proposed rule for how to submit your comments. You have until August 21, 2017, to get your word in. CMS has specific instructions on how to respond. While they won’t take FAXs, they give four other ways to comment:

  • Electronically through Regulations.gov
  • Regular mail
  • Express or overnight mail
  • Hand or Courier

Make sure to refer to file code CMS 5522-P, whichever way you choose to respond.

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