We're still reading through the 2,398-page MACRA final rule, so it’s hard to summarize what the rule will mean for providers. Here are our three initial big takeaways from the final rule, compared with the proposed rule.
Clinicians will find it far easier to comply with MIPS in 2017
As the agency had previously previewed, the final rule includes significant flexibility for providers in the first year, to the point that most—if not all—clinicians should be able to avoid a negative payment adjustment for performance year 2017. CMS proposes three options for providers subject to MIPS in 2017, the easiest of which providers can meet by reporting a single metric. CMS has also raised the low-volume threshold, exempting more small practices from MIPS.
In addition, providers will not be scored on the resource use category in 2017 and can satisfy full-year reporting requirements by reporting for a 90-day period.
However, it's important to note that requirements will ramp up over time. CMS states, "In future years of the program, we will require longer performance periods and higher performance in order to avoid a negative MIPS payment adjustment."
More providers will qualify for the APM track
The final rule should increase the number of providers who qualify for the APM track. For instance, CMS included changes to financial criteria for APM models and plans to introduce a new qualifying model—called ACO Track 1+—in 2018. Notably, however, Track 1 of the Medicare Shared Savings Program will still not qualify for the APM track.
The changes announced on Friday, coupled with changes to CMS' mandatory bundled payment initiatives, led CMS to estimate that as many as 120,000 clinicians will qualify for the APM track in 2017. And CMS estimates that by 2018, about 25 percent of eligible Medicare clinicians could be in an advanced APM.
The agency is showing a big commitment to reducing administrative burden
Last Thursday, CMS unveiled an initiative to re-examine more broadly clinician reporting requirements in Medicare, and Friday's release of the final rule fits with that. For instance, the agency said it will synchronize quality measures and practice-specific improvement activities in MIPS so they don't pull providers in different directions. The $100 million in funding over five years that CMS will use for technical support to small practices should also be extremely helpful for those organizations.
These moves to reduce administrative burden should shift providers' risk in the program from reporting to performance. By enabling more providers to satisfy reporting requirements, providers will only be able to differentiate themselves through their level of performance on the metrics.
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