Organizations and companies throughout healthcare were scrambling Friday to ingest the massive new final rule for the Medicare Access and CHIP Reauthorization Act (MACRA) Quality Payment Program.

The crucial rule, contained in nearly 2,400 pages of detailed description, revamps physician reimbursement to reflect quality and efficiency of care, and makes changes to the Electronic Health Records Meaningful Use Program.

The final MACRA rule imposes far less financial risk on physicians than the proposed rule issued earlier this year, says Travis Broome, health policy lead at Aledade, a company that partners with primary care physicians to develop accountable care organizations.

Travis Broome
Travis Broome

The final rule changes the definition of financial risk to make it more two-sided—with Medicare and physicians assuming risk, and not everything falling on the physicians, which makes ACO participation more viable.

For physicians not yet ready for ACOs, Medicare in the final rule is offering a “transition year,” in 2017, Broome adds. That means these physicians need only to report at least one quality measure to avoid a payment penalty. And if they are ready for the leap to an ACO or other value-based programs, physicians in 2017 can generate higher Medicare payments. In 2018, full year reporting of quality measures will be required.

Several industry associations have released initial statements on the provisions within the final MACRA rule. They include:

Medical Group Management Association
“MGMA is pleased with the significant burden reduction for physician practices in the first year of the MIPs program and new alternative payment model options outlined in the final rule. It’s disappointing that flexibility provided for quality reporting in 2017 largely disappears in 2018 and beyond. The Centers for Medicare and Medicaid Services missed an opportunity to close the two-year gap between the measurement and payment periods, which would facilitate improved patient care by providing actionable feedback to physicians and more timely incentives. The sheer magnitude of a 2,400-page regulation and its impact on physician practices can’t be ignored.”

American Medical Informatics Association
“CMS has crafted a set of policies that are strategic, flexible and reflective of feedback from the informatics community. AMIA recommended that CMS provide physicians with an on-ramp to participation in 2017 and they have responded with a strategy that will do just that. Beginning with a much-needed “transition year” for participation and inclusive of an across-the-board reduction in scope, this final rule with comment period will ensure that success is within reach of every eligible clinician.

“Members of the Premier alliance strongly support the potential of the Quality Payment Program under the Centers for Medicare & Medicaid Services (CMS) Medicare Access and CHIP Reauthorization Act (MACRA) to help fix the misaligned incentives in Medicare’s traditional fee-for-service program. Premier is an ardent supporter of a transition away from fee-for-service and toward a model where providers are accountable and rewarded for high-quality, cost-effective care. CMS wisely allowed a gradual transition to this pay for performance reality, striking a good balance overall.

“While we are pleased that CMS eased the policy defining the Advanced APM to allow additional programs to qualify and has signaled it will increase the number of available models, the nominal risk standard remains way too high. As we have learned from members in our Bundled Payment and Population Health Management Collaboratives, these models require significant investment in redesigning care through new technologies, data analytics, and additional staff. CMS has chosen to ignore these realities. We call on CMS to rethink this risk standard in future rules to incent greater participation. We also call on CMS to accelerate recognition of “virtual” physician groups that would allow small practices to band together using technology to meet the minimum thresholds and comply with reporting requirements.

“CMS did the right thing by creating an accelerated timeline for determining whether clinicians meet the standards for the Advanced Alternative Payment Model (Advanced APM) before the end of the Merit-based Incentive Payment System (MIPS) performance period. This mitigates the uncertainty and added administrative work for ACOs and other organizations who otherwise would have reported through MIPS in the absence of certainty about whether they met the Advanced APM thresholds.

“While we are still reviewing the 2,400-page rule, the Centers for Medicare and Medicaid Services today seemed to take important steps in giving physicians much-needed flexibility for adopting health information technology as they transition to a new payment model. For instance, the final rule reduces the reporting burden on clinicians by giving them the option of a 90-day reporting period, or a full year. It also reduces the number of measures upon which clinicians must report.

“Unfortunately, CMS appears to have retained stringent language requiring hospitals and clinicians to attest that they are not engaging in information blocking. The agency does, however, clarify that providers ‘should not be held responsible for adherence to health IT certification standards or other technical details of health IT implementation that are beyond their expertise or control.’

“Meanwhile, the Office of the National Coordinator for Health IT today finalized a rule covering certification and oversight of certified health information technology. CHIME appreciates that steps that the agency is taking to increase transparency of health IT performance. Hospitals and clinicians must have confidence that the products they purchase work as intended and do not pose a significant risk to patient safety or public health.