CMS Issues MACRA Final Rule

By David White

If you have been waiting for the final rule from Medicare on MACRA (the Medicare Access and CHIP Reauthorization Act) before taking any steps, your wait is over. The new physician payment system is out: Medicare is calling it the Quality Payment Program (QPP).  Think of it this way: MACRA was the law and the Quality Payment Program is the new program the law created. 

ASN is assessing the new QPP and will be regularly releasing new information about the program, detailed in a 2,398 page final rule, with the goal of providing access to credible information, practical material, and available resources found on the ASN MACRA Resource Page.  There are a few important details that you should know before the program begins January 1, 2017.

Who's in the Quality Payment Program?

You will be in the Quality Payment Program if you bill Medicare more than $30,000 a year or provide care for more than 100 Medicare patients a year, and are a:

Physician

Physician assistant

Nurse practitioner

Clinical nurse specialist

Certified registered nurse anesthetist

However, if 2017 is your first year participating in Medicare, then you will not be in the MIPS track of the Quality Payment Program.

Performance Period:

The first performance period begins January 1, 2017 and closes December 31, 2017 for adjustments in CY 2019. During 2017, record your quality data and how you used technology to support your practice. If you are in an Advanced APM, then you can provide care during the year through that model. 

Reporting Performance Data and Avoiding Penalties:

To potentially earn a positive payment adjustment under MIPS or avoid a penalty, send in data about the care you provided and how your practice used technology in 2017 to MIPS by the deadline, March 31, 2018. In order to earn the 5% incentive payment for participating in an Advanced APM, just send quality data through your Advanced APM.  Medicare gives you feedback about your performance after you submit your data.

When does the Quality Payment Program start?

You get to pick your own pace for the Quality Payment Program. If you are ready, you can begin January 1, 2017 and start collecting your performance data. If you're not ready on January 1, you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you'll need to send in your performance data by March 31, 2018.  The first payment adjustments based on performance go into effect on January 1, 2019.

How will the Quality Payment Program change your Medicare payments?

It is important to remember these details are only for payment adjustments in 2019.  Medicare will issue new guidelines for 2020 and beyond.  Here’s how it is going to work:

If you choose not to participate in the Quality Payment Program

If you do not send in any 2017 data, then you receive a negative 4% payment adjustment in 2019.

Testing

If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point in 2017), you can avoid a downward payment adjustment.

Partial Participation

If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.

Full Participation

If you submit a full year of 2017 data to Medicare, you may earn a moderate positive payment adjustment.

These are a few highlights.  ASN will be regularly providing updates and access to information at the ASN MACRA Resource Page.

KN Online provides general MACRA backgrouund and resources here.

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If you have been waiting for the final rule from Medicare on MACRA (the Medicare Access and CHIP Reauthorization Act) before taking any steps, your wait is over. The new physician payment system is out: Medicare is calling it the Quality Payment Program (QPP).  Think of it this way: MACRA was the law and the Quality Payment Program is the new program the law created. 

ASN is assessing the new QPP and will be regularly releasing new information about the program, detailed in a 2,398 page final rule, with the goal of providing access to credible information, practical material, and available resources found on the ASN MACRA Resource Page.  There are a few important details that you should know before the program begins January 1, 2017.

Who's in the Quality Payment Program?

You will be in the Quality Payment Program if you bill Medicare more than $30,000 a year or provide care for more than 100 Medicare patients a year, and are a:

Physician

Physician assistant

Nurse practitioner

Clinical nurse specialist

Certified registered nurse anesthetist

However, if 2017 is your first year participating in Medicare, then you will not be in the MIPS track of the Quality Payment Program.

Performance Period:

The first performance period begins January 1, 2017 and closes December 31, 2017 for adjustments in CY 2019. During 2017, record your quality data and how you used technology to support your practice. If you are in an Advanced APM, then you can provide care during the year through that model. 

Reporting Performance Data and Avoiding Penalties:

To potentially earn a positive payment adjustment under MIPS or avoid a penalty, send in data about the care you provided and how your practice used technology in 2017 to MIPS by the deadline, March 31, 2018. In order to earn the 5% incentive payment for participating in an Advanced APM, just send quality data through your Advanced APM.  Medicare gives you feedback about your performance after you submit your data.

When does the Quality Payment Program start?

You get to pick your own pace for the Quality Payment Program. If you are ready, you can begin January 1, 2017 and start collecting your performance data. If you're not ready on January 1, you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you'll need to send in your performance data by March 31, 2018.  The first payment adjustments based on performance go into effect on January 1, 2019.

How will the Quality Payment Program change your Medicare payments?

It is important to remember these details are only for payment adjustments in 2019.  Medicare will issue new guidelines for 2020 and beyond.  Here’s how it is going to work:

If you choose not to participate in the Quality Payment Program

If you do not send in any 2017 data, then you receive a negative 4% payment adjustment in 2019.

Testing

If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point in 2017), you can avoid a downward payment adjustment.

Partial Participation

If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.

Full Participation

If you submit a full year of 2017 data to Medicare, you may earn a moderate positive payment adjustment.

These are a few highlights.  ASN will be regularly providing updates and access to information at the ASN MACRA Resource Page.

KN Online provides general MACRA backgrouund and resources here.