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MACRA, MIPS, and Advanced APMs

Last Updated: Jan 19, 2017 09:47AM PST

What is MACRA?
MIPS vs Advanced APMs
Who can Participate?
MACRA in 2017
MIPS
Advanced APMs

IMPORTANT: Elation has created a MIPS slide deck and MIPS guide to help practices digest the complex MACRA Final Rule. We encourage you to check out both attachments to help you understand MACRA and MIPS.

What is MACRA?

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repeals the Medicare Sustainable Growth Rate and replaces it with a new program known as the Quality Payment Program (QPP).
Beginning on January 1st, 2017, qualified providers will participate in one of two tracks, either Advanced Alternative Payment Models (Advanced APMs) or the Merit-based Incentive Payment Program (MIPS).

 

MIPS vs Advanced APMs

MIPS
Mips is the standard track that applies to most physicians, and is based directly on the traditional Medicare Fee-for-Service schedule. 

  

Advanced APMs
Advanced APMs are unique payment programs that replace or heavily augment how providers are paid. A few examples are CPC+ and Medicare Shared Savings Program Track 2

  • Payment Track for ~95% of Physicians.
  • Replaces Meaningful Use (MU), PQRS, and Value Based Payment Modifier (VM)
  • Adjustments to Medicare payments based on performance, varying by program year:
    • 2019: +/- 4%
    • 2020: +/- 5%
    • 2021: +/- 7%
    • 2022: +/- 9%
  • Additional incentive from $500 Million pool to provide positive adjustments to
 
  • Payment Track for ~5% of Physicians.
  • Exempt from MIPS Incentives and Penalties
  • 5% annual payment bonus between 2019 and 2024
  • Multiple payment structures.

 

Who can Participate?

The majority of physicians in the US will be subject to MIPS, unless they fall into one of the following categories

  • New Medicare Providers are exempt if it is their first year receiving Medicare payments.
  • Practices participating in an Advanced APM are exempt from MIPS.
  • Any practice with less than $30,000 in Medicare Part B allowed charges or with less than 100 Medicare patients are exempt.
 

MACRA in 2017

In order to facilitate a smooth transition to MIPS, 2017 will serve as a Transition Year, with a number of temporary provisions available to help providers succeed.

  1. Providers can pick their pace of participation from the following options:
    1. Full Year: Providers who submit a full year of MIPS data may receive a moderate payment adjustment.
    2. Partial Year: Providers can only submit 90 days of MIPS data in 2017, and will receive no negative adjustment, or a small positive adjustment
    3. Test: Providers can only submit the minimum amount of data (e.g. one quality measure, or one improvement activity) and receive no negative payment adjustment.
  2. Additional Advanced APMs will be available to providers.
  3. Performance threshold is lowered to 3 points.
  4. Providers who score 70 or higher will be eligible for an exceptional performance adjustment.
  5. The cost performance category of MIPS has its weight lowered to 0% (down from 10%).
  6. For the Advancing Care Information objective, clinicians only need to report on required measures to meet the performance threshold
 

MIPS

Providers who opt not to participate in an Advanced APM will participate in the Merit-based Incentive Payment System (MIPS), which continues the traditional Medicare Fee-for-Service structure. MIPS replaces the existing Meaningful Use (MU), PQRS, and Value Based Payment Modifier (VM) programs, and combines them into a single program with 4 weighted categories determining participants payment adjustments.


 

Advanced APMs

Advanced APMs can come in a number of forms, however CMS predicts the following being the most relevant in 2017:

  • Comprehensive End Stage Renal Disease Care Model (Two-Sided Risk Arrangements)
  • Medicare Shared Savings Program Track 2
  • Comprehensive Primary Care Plus (CPC+)
  • Medicare Shared Savings Program Track 3
  • Next Generation ACO Model

This list is subject to change, and CMS will post the final list of approved Advanced APMs bu January, 1 2017.

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