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March 31, 2016

MACRA Progress Report: Subcommittee on Health Hearing

According to Politico the draft rule for the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) has been sent to the Office of Management and Budget (OMB) at the White House for review.   Which means the draft rule should be released sometime in April.

The Subcommittee on Health of the Committee on Energy and Commerce recently held a hearing, focused on MACRA and how to implement Medicare payment reforms. Dr. Patrick Conway, the Deputy Administrator for Innovation and Quality and Chief Medical Officer at the Centers for Medicare and Medicaid Services (CMS) was present as a witness, offering testimony on the progress CMS has made as well as future changes CMS would like to see made.

Background

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is the product of years of bipartisan work to repeal the Sustainable Growth Rate (SGR). MACRA permanently repealed the SGR formula and somewhat provides stability in Medicare base payments through 2019. MACRA alters how the Medicare program pays for services, as well as how providers interact with Medicare.

Not only did MACRA attempt to respond to criticism about how providers are reimbursed, how they interact with the program, the development of new quality measures and means of evaluating and integrating new practice models into the system, but it was also meant to add a layer of transparency into the development and operation of how Medicare reimburses providers.

MACRA provides for updates to the fee schedule of .5% from July 2015 through 2019, at which point services on the physician fee schedule will remain at the 2019 level and be adjusted based on a provider's participation in MIPS or a qualifying APM. After 2026, providers participating in a qualified APM will receive a .75% update and all others will receive a .25% update.

Instead of applying the typical "one size fits all approach," MACRA allows eligible professionals and eligible organizations to identify quality measures and then tailor the quality measures that best fit their individual practice and specialty. Eligible professionals are assessed only on the categories that apply to them, and the categories may be reweighted to compensate, as needed. Each year, the Secretary will establish a performance threshold based on the performance of all participating eligible professionals, who will be informed of how they performed in the prior period and what performance threshold they must meet to be eligible for incentive payments and to avoid penalties. Additionally, eligible professionals who scores fall into a high performance category will receive an additional bonus payment, and providers who make notable gains in performance will be rewarded.

Hearing Discussion

Reporting Period Length

One of the important topics discussed during the hearing was what the best time period is for physicians to submit their quality reports to Medicare. According to Dr. Conway, historically, CMS has "had a performance period that is twelve months, and often providers wanted three to four months to finish reporting on quality measures." Dr. Conway explained that currently, "providers are reporting quality measures now through middle of April" and that "payments end up being made about twelve months after the end of the performance period, or eight months after they finish reporting quality measures."

Dr. Conway testified that several years back, CMS asked physician and clinician groups if they wanted to have similar reporting periods to hospitals, who submit quarterly reports, which allows for more rapid feedback. Many of the physician and clinician groups were not interested in a quarterly reporting cycle, they like the annual reporting cycle.

Today, groups like the American Academy of Family Physicians are actually calling for CMS to announce a 90-day reporting period as soon as possible. AAFP is concerned that requiring physicians to report performance measurements for an entire year "would hinder efforts to prepare for the transition to new payment models" outlined by MACRA. AAFP claims that a shorter reporting period would allow physicians to update their technology and improve interoperability with other institutions.

MIPS Flexibility is Key

Dr. Conway and Rep. Kathy Castor went back and forth a bit on how MIPS makes things easier for providers. Dr. Conway stated that it's truly the flexibility of MIPS, which allows CMS to lower the burden on physicians, makes data collection more meaningful, and part of the normal workflow.

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