The final rule for MACRA Year 2 was released on Nov. 2, giving MACRA eligible clinicians (ECs) two months to finalize their Year 2 game plan.
But if the struggles they faced in understanding Year 1 requirements are any indication, it will take intense training for them to feel ready to take the MACRA playing field this year.
Six months into MACRA Year 1, an American Medical Association (AMA) survey found more than 75 percent of physicians felt unprepared to meet the Quality Payment Program (QPP) requirements, in spite of the “pick your pace” options for participation. Only 51 percent of those with decision-making authority for their practices said they felt “somewhat knowledgeable” about MACRA. Just 8 percent described themselves as “deeply knowledgeable.”
Closing the MACRA knowledge gap must be a key strategy for medical groups and physician practices during MACRA Year 2. Here’s what practice leaders should know.
Going the Distance in MACRA Year 2
Much of what MACRA ECs disliked about MACRA Year 1 was the level of difficulty in meeting program requirements. More than half of physicians who responded to the AMA survey called the requirements “overly burdensome.” The changes we’ll see in MACRA Year 2 demonstrate the Centers for Medicare & Medicaid Services (CMS) moved to simplify the program based on providers’ feedback.
“During my visits with clinicians across the country, I’ve heard many concerns about the impact burdensome regulations have on their ability to care for patients,” CMS administrator Seema Verma said when the final rule was released. The MACRA Year 2 requirements “begin to ease that burden,” she said.
Highlights of MACRA Year 2 include the following.
Greater flexibility for small practices. Now, individual ECs or groups with less than or equal to $90,000 in Medicare Part B allowed charges, or less than or equal to 200 Medicare Part B patients, will not be required to participate. That’s double the number of patients formerly required for participation and three times the threshold for Medicare Part B charges in Year 1. Additionally, during MACRA Year 2, CMS will:
• Add five bonus points to the scores of small practices that report data in at least one performance category
• Give individual practitioners and small practices the option to form or join a Virtual Group to report under the Merit-based Incentive Payment System (MIPS) track, significantly reducing the reporting burden by enabling small groups to share the costs of participation
• Continue to award small practices three points for measures in the Quality performance category that do not meet data completeness requirements
• Add a new hardship exception for the Advancing Care Information (ACI) category of MIPS: ECs and groups who show that demonstrating Meaningful Use would pose a hardship could gain an exemption valid for one payment year and can reapply for an exception up to four more times
Increased performance threshold. CMS raised the MACRA performance threshold to 15 points in Year 2, up from three points in Year 1. Additionally, performance under the cost category of MIPS will comprise 10 percent of ECs’ score. This score will be determined using Medicare Spending per Beneficiary and total per capita cost measures and will be calculated by CMS.
Greater opportunities to earn bonus points. Under MACRA Year 2, ECs in both the MIPS and Advanced Alternative Payment Model (APM) tracks can use 2014 certified electronic health record technology (CEHRT) systems for one more year, but they’ll get bonus points for using 2015 CEHRT systems exclusively. Providers also will get extra points if they can prove they care for especially complex patients.
Relief for ECs impacted by hurricanes. If, during MACRA Year 1, an EC or group was unable to access its electronic health record (EHR) due to “extreme and uncontrollable circumstances,” including hurricanes, other natural disasters and public health emergencies, the clinician or group may apply for a hardship exception. If approved, the ACI score for the clinician or group would be reweighted.
Increased potential to participate in APMs. Under the final rule, ECs or groups will have new opportunities to participate in select APMs, known as Advanced APMs—and achieve the 5 percent APM bonus. For example:
• The final rule makes it easier for clinicians to qualify for incentive payments by participating in Advanced APMs that begin or end in the middle of the year.
• The All-Payer Combination Option gives providers in Advanced APMs that do not meet the Medicare thresholds an opportunity to include Other Payer Advanced APMs in their reporting to meet the minimum threshold for performance. This option will be available in 2019.
Staying Ahead in the Game in 2018
Given the challenges ECs faced in understanding MACRA and its reporting requirements in Year 1, practice leaders should take strategic action and steps to support success in Year 2.
Eligible practices should work to close their MACRA knowledge gap and improve their chances of earning an incentive. For most physicians surveyed, earning an incentive is their goal under MACRA. This goal is best accomplished when physicians and clinicians are fully engaged and informed and understand their role in meeting the MACRA reporting requirements.
Physician practices also should strive to better leverage their EHR to gain an advantage in meeting the MACRA requirements. For example, benchmarks for quality measures vary by submission method, resulting in different scores. If your practice has chosen to submit its MACRA performance data via an EHR, software capabilities that support MACRA reporting are critical.
Learn more by downloading the CMS Fact Sheet for the MACRA Year 2 final rule.
About the author:
Sonya Bess is a government initiative project manager at Pulse, Inc.
The views, opinions and positions expressed within these guest posts are those of the author alone and do not represent those of Becker's Hospital Review/Becker's Healthcare. The accuracy, completeness and validity of any statements made within this article are not guaranteed. We accept no liability for any errors, omissions or representations. The copyright of this content belongs to the author and any liability with regards to infringement of intellectual property rights remains with them.