.jpg)
Starting in 2015 through 2019, the annual Physician Fee Schedule increase will be one-half of one percent (0.5%). Thereafter, the reimbursement rate paid to each healthcare professional will be adjusted to reflect his or her performance under what MACRA calls a Merit-Based Payment Incentive System ("MIPS"), which focuses on 4 areas:
– Quality;
– Resource use/efficiency;
– Meaningful use of electronic health records; and
– Clinical practice improvements.
CMS will seek input from outside groups in determining the specific areas that will be measured, in order to evaluate several quality measures, including:
– Clinical care;
– Safety care coordination;
– Experience of patients and their caregivers; and
– Population health management.
Healthcare professionals will receive reimbursement rate increases (or decreases) if their MIPS composite scores exceed (or fall below) the "average"; how that will be determined is not clear. Between 2019 and 2024, the total amount available annually for increases will be $500 million. Healthcare professionals whose composite scores fall below the average may see their reimbursement reduced by as much as 4 percent in 2019, 5 percent in 2020, 7 percent in 2021 and 9 percent in 2022.
CMS is tasked with providing quarterly data to each healthcare professional regarding their MIPS performance. This raises a number of questions, including:
– Will CMS have the resources to accomplish this goal?
– What are the consequences if the agency does not?
– Will the MIPS "average" mean half of the healthcare professionals who participate in the Medicare program, almost by definition, sustain reimbursement rate reductions every year?
Healthcare professionals who receive a "substantial portion" of their reimbursement through Alternative Payment Models ("APM") (or treat few Medicare beneficiaries) will be exempt from MIPS; exactly what will constitute a "substantial portion" has yet to be determined. APMs, like Medicare participating accountable care organizations ("ACOs") and patient-centered medical homes ("PCMH"), are providers that bear both a risk of financial loss and an obligation to meet their own quality measurements. Healthcare professionals who qualify for inclusion in this exemption will receive a reimbursement rate bonus of up to 5 percent (5%) in 2019. It seems likely the APM exception will serve as an incentive for healthcare professionals to join APMs.
In a Congressional session where little is expected, the two political parties and the two Houses of Congress have found something substantive in the healthcare arena on which to agree – a way to replace SGR. Only time will tell whether MACRA will promote the recovery for healthcare professionals’ fortunes and improve the healthcare delivery system.