MACRA 2.0: are you ready for MIPS?

Abstract

The annual cost of healthcare delivery in the USA now exceeds US$3 trillion. Fee for service methodology is often implicated as a cause of this exceedingly high figure. The Affordable Care Act created the Center for Medicare and Medicaid Innovation (CMMI) to pilot test value based alternative payments for reimbursing physician services. In 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) was passed into law. MACRA has dramatic implications for all US based healthcare providers. MACRA permanently repealed the Medicare Sustainable Growth Rate so as to stabilize physician part B Medicare payments, consolidated pre-existing federal performance programs into the Merit based Incentive Payments System (MIPS), and legislatively mandated new approaches to paying clinicians. Neurointerventionalists will predominantly participate in MIPS. MIPS unifies, updates, and streamlines previously existing federal performance programs, thereby reducing onerous redundancies and overall administrative burden, while consolidating performance based payment adjustments. While MIPS may be perceived as a straightforward continuation of fee for service methodology with performance modifiers, MIPS is better viewed as a stepping stone toward eventually adopting alternative payment models in later years. In October 2016, the Centers for Medicare and Medicaid Services (CMS) released a final rule for MACRA implementation, providing greater clarity regarding 2017 requirements. The final rule provides a range of options for easing MIPS reporting requirements in the first performance year. Nonetheless, taking the newly offered 'minimum possible' approach toward meeting the requirements will still have negative consequences for providers.

The Qualified Clinical Data Registry: A Pathway to Success within MACRA

“…26 Members of the American Society of Neuroradiology will be well positioned to participate in the NRDR, Neurovascular Quality Initiative, or North American Spine Society Spine Registry. 27…”

“…Further details of this scoring system have been previously described and are beyond the scope of this review. 27 MIPS will adjust payments based on the actual level of performance within each category, measure, and activity. In the MIPS Quality category, participating clinicians will be required to submit 6 quality metrics, including 1 outcome measure if available.…”

“…Physicians who do not participate in MIPS reporting may be perceived as inferior to their peers using this platform. 27 This level of public transparency through this tool further increases the importance for radiologists to pursue actions, such as the use of QCDRs, to ensure their success under MIPS.…”

Merit-Based Incentive Payment System: Meaningful Changes in the Final Rule Brings Cautious Optimism

“…On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released the highly anticipated, controversial, final rule for implementation of Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, with the inclusion of responses to numerous comments from the public, Congress, and providers (1,2). This rule changed many aspects of the proposed rule, providing the final description in detail of the physician payment system that Congress outlined in MACRA (3)(4)(5)(6)(7)(8)(9)(10)(11)(12)). As we have described in detail in our previous manuscripts, MACRA and Merit-Based Incentive Payment System (MIPS) Medicare Physician Payment System will, starting in 2019, placemost physicians in the MIPS, a pay for performance system that adjusts payments based on measures derived from prior care (3)(4)(5)(9)(10)(11)(12).…”

Reframing Medicare Physician Payment Policy for 2019: A Look at Proposed Policy

“…This is in contrast to the 2017 proposed rule at which time the Obama administration had declared the success of the Patient Protection and Affordable Care Act (ACA) with significant progress towards solving longstanding challenges facing the US health care system related to access, affordability, and quality of care (2)(3)(4)(5)(6)(7)(8)). As we have described in the past, reducing health care expenditures with increased access to affordable insurance coverage and improvement in quality have been the cornerstones of multiple legislative efforts and regulations including the ACA (4)(5)(6)(7)(8)(9)(10)(11)(12)(13)(14)(15)(16)(17)(18). Despite the fact that there are clear examples of program success, the effectiveness of ACA in achieving some of its primary goals has been questioned (5,8).…”