MACRA proposed rules provide some clarity, but questions remain

In a recent blog post, ECG Management Consultants discusses the proposed rules for the Medicare Access and CHIP Reauthorization Act (MACRA).

Last week CMS released its much-anticipated proposed rules for the Medicare Access and CHIP Reauthorization Act (MACRA), which was passed by Congress approximately 1 year ago and introduced substantive changes in the way Medicare will reimburse physician services. Readers of previous ECG blog posts and articles may recall that, like the ACA before it, this legislation grants the HHS Secretary great latitude in fleshing out the details through rulemaking. While these are only proposed rules, and CMS is using this as an opportunity to solicit commentary from the public, they do shed light on what we can expect when the rules are finalized in November.

MACRA establishes two tracks for reimbursement: the Merit-Based Incentive Payment System (MIPS), which resembles the current Physician Fee Schedule, and Alternative Payment Models (APMs), which encourage a greater level of innovation coupled with stronger financial incentives. The proposed rules provide greater clarity on each of these tracks while leaving some details to be determined.

MIPS Details Revealed

Of the two tracks, MIPS was the more clearly defined in the original MACRA legislation. This remains the case, as the proposed rules give a great deal of additional information about how this track will be administered. Some of the key questions that have been addressed (though not finalized) are listed below.

Timing of Payment Adjustments

As we expected, it looks like there will be a 2-year time lag between the performance period and the payment period. That is, since payment adjustments begin in 2019, they will be based on performance during calendar year 2017. That means that providers will have little time to adjust their performance because the measures won’t be finalized until November of this year. Fortunately, for the quality incentive, which represents 50% of the total incentive in the first year, no new measures will be introduced this year from the existing PQRS system on which it is based.

See the full blog post here.

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