As we start rounding the corner and heading towards the end of the year, we know that it is a time of reflection and final proposals. The Centers of Medicaid and Medicare (CMS) announced this month the final rules for the second performance year under Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). With this announcement comes a feeling of uncertainty but surely a feeling of progression. Value Based Care is a continuum from the fee-for-service world up to a full capitation or global payment type structure. Various organization lay somewhere between that continuum. What CMS is attempting to do is enact legislation in palatable steps so we can learn as a group to figure out what works and what doesn’t.
When MACRA was announced, we knew that the demands were high for many providers that have not been a part of any value based payment innovation project such as ACOs or Bundled Payments. That said, they listened to comments from healthcare stakeholders and made the first performance year of 2017 one with modified demands such as a range for completing quality metrics (none to all). The results from year 1 have yet to be announced but in the meantime, we know that CMS is pushing providers in the direction of value based care. Therefore, they have announced the changes for the second performance year. CMS wants to ensure four things:
- The program’s measures and activities are meaningful
- Clinician burden is minimized
- Care coordination is better
- Clinicians have a clear way to participate in advanced APMs (Alternative Payment Mechanisms)
With these four items in mind, they announced that the second year of transition will keep many of the flexibilities from the first year such as limiting those providers that have less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries. The Certified Electronic Health Record Technology (CEHRT) is allowing the use of 2014 or 2015 editions and giving a bonus for 2015s. Additionally they will be adding more options for small practices so that they can participate in the Merit Based Payment System (MIPS) in order to keep up with the movement from fee for service to the various value based payment options.
Being a part of MIPS is the smallest baby step on the continuum, but it is clear to see that MACRA is truly an attempt to push those on the lower end of the continuum up further into APMs. Being a part of an ACO, Bundled Payment, Patient Centered Medical Home and various other programs that are already undertaking the move towards risk are rewarded right off the bat for participation with a 5% increase in overall Medicare reimbursement payments with fewer burdens for reporting. Hopefully, providers begin to see that the wave of change is underway and that resistance will only create obsolescence. You need to take baby steps like joining a track 1 ACO with only upside risk to ensure the proper projection along the continuum of value based care to succeed.
