The healthcare industry has been caught up in the excitement of physician payment reform, but one industry expert notes that much uncertainty lies ahead for the proposed rule and its provisions are hardly a fait accompli.
The final form of the final rule is still uncertain; federal agencies may take a while to finalize the details in advance of the expected effective date; and the impact of the transition of power in the White House has yet to be factored in, says Chris Emper, vice president of government affairs at NextGen Healthcare Systems, a physician software vendor.
As it now stands, the proposed Medicare Access and CHIP Reauthorization Act (MACRA), which includes the new Merit-based Incentive Payment System (MIPS) for Medicare physicians, is expected to go into effect on January 1, but that assumes that Centers for Medicare and Medicaid Services can finalize the MACRA rule by then, Emper says.
Whether the rule can be finalized this year is a risky proposition. The rule pertains only to Medicare physicians, but CMS and Congress have expressed a desire to align other meaningful use programs for physicians as well as hospitals, but cannot do so absent legislation, which is unlikely to occur in this election year, Emper says.
Presidential elections, and the certainty that a new administration is entering the White House, also could throw a wrench into enactment of the new reimbursement system.
Traditionally, new presidential administrations have puts a hold on federal rules proposed or recently finalized by previous administrations, until those newly enacted rules can be reviewed.
Emper says it’s possible that even if MACRA and MIPS went into effect on January 1, it could be put on hold by the new administration three weeks later. However, he believes that a delay of the reforms would be unlikely, because Congress has overwhelmingly supported the need for reimbursement reform.
Still, if all changes associated with reimbursement changes take hold, Emper believes there is a considerable financial upside in physician reimbursements awaiting doctors. Based on MIPS performance in 2017, physicians could get a 12 percent increase in Medicare reimbursement in 2019, with that increase rising over the next three years to as much as 27 percent in 2022. Medicare physician who do not participate would see maximum reimbursement cuts of four percent in 2019, five percent in 2020, seven percent in 2021 and nine percent in 2022.
Physician practices with a low percentage of Medicare patients may not argue about accepting the lower payments, Emper says. But it remains to be seen whether many physicians realize the payment changes coming, he adds. “Your average physician does not understand the payment adjustments, and CMS hasn’t explained it well.”
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