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MACRA: The Final Rule and What it Means (Part 1 of 2)

 After much anticipation (and, let’s be honest, anxiety from parties on all sides), the Department of Health and Human Services and the Centers for Medicare and Medicaid Services (CMS) released the final rule on the Medicare Access and Chip Reauthorization Act of 2015 (MACRA) in mid-October.

If you didn’t read the entirety of the 2,398-page document, you’re not alone. The sheer volume of information was daunting to many in the industry, causing publications and professional organizations to do their best to highlight the key points contained within the rule.

And so, after scouring many of these articles and summaries, here are several key points that you should know about MACRA.

There will still be a lot of reporting

If you check the comments on many articles about the MACRA final rule, the top issue is the amount of reporting still required and the concern that this administrative work is taking away from actual time with patients.

And that’s the bad news in all of this. While CMS acting administrator Andy Slavitt says that compared to Meaningful Use, reporting will be significantly cut under MIPS — the Merit-based Incentive Payment System — there will still be reporting involved. And a lot of it.

“CMS estimated in the proposed rule that it would take roughly 7-18 hours, depending on the complexity of the submission, for a practice to submit quality data for one clinician,” writes Leigh Page in an article on Medscape (http://www.medscape.com/viewarticle/870517).

“The total reporting burden for quality measures, such as the Physician Quality Reporting System (PQRS), is even higher, according to a recent study in Health Affairs. Primary care, cardiology, orthopedics, and multispecialty practices spent an average of 19.1 hours per physician per week on quality measurement, and physicians themselves spent almost 4 hours per week on this work.”

Take a group route?

There were several pieces of information in the final rule that were favorable to small physician practices and clinics, one of which being the ability to report as a group instead of as an individual.

According to Jeff Byers of HealthcareDive (http://www.healthcaredive.com/news/here-are-the-macra-final-rule-changes-you-need-to-know/428341/), CMS is allowing “a set of clinicians sharing a common Tax Identification Number, no matter the specialty or practice site” to report together.

“This could help small providers of similar size to band together to receive a payment adjustment based on the group’s performance,” Byers writes.

Medscape’s Page adds that this proposed rule would also “allow practices with 10 or fewer physicians to join virtual groups,” but this won’t be implemented until the after the first year.

“Virtual groups are a very interesting concept, but the devil is in the details,” Maria Calamaro, a product director for a billing and coding company says in the Medscape article. “It would be hard to aggregate data if members of the group use different electronic health record (EHR) systems and other technology.”

So, there are definitely challenges, but this appears to be a promising step for smaller practices.

Staying out will hurt your income and reputation

Second only to the comments on the amount of administrative work are those who are saying that opting out of MIPS and taking the penalty is a better way of working.

Here’s the logic — if the penalty is cheaper than the amount it would cost the practice to comply with PQRS reporting, why report at all? After all, this is voluntary reporting.

While this may have been true under Meaningful Use, there are two primary reasons why you should reconsider if you’re thinking about opting out — which many are.

First, while the penalties will be dropping at first as the healthcare industry goes through the transitional period, the penalties will begin rising eventually to a proposed 9 percent in 2022 and thereafter. 

But second, and maybe just as importantly, is that your MACRA and MIPS scores are likely to be posted on a CMS website that compares physicians.

“If you’re a low performer, everyone will know your score,” says Greg Fulton, an industry and public policy lead at a value-based care company in Georgia (http://www.medscape.com/viewarticle/870517_3). “Not just patients, but also prospective partners and employers.”

Something is better than nothing

2017 will be considered as a transitional year. That means — according to Slavitt — that CMS is attempting to make the transition “as simple and as flexible as possible.” Reporting requirements are lower and reporting timing is flexible.

If you’re comfortable to begin collecting data on January 1, that’s great. But you have the ability to begin your data collection anytime between January 1 and October 2.

Or, as Byers puts it: “You have to do something in 2017” (http://www.healthcaredive.com/news/here-are-the-macra-final-rule-changes-you-need-to-know/428341/). And as long as you do something, you’re less likely to face any sort of penalty.

There is help if you need it

And finally, if all of this feels completely overwhelming, here’s some good news — there are plenty of sources of help to get you through this transition. 

  • According to Page, MACRA is providing $20 million a year for training organizations to help small practices as well.

Don’t be afraid to seek help as you need it. It’s better to have extra assistance than to stress out over whether or not you’ve done everything properly.