It is reported that MIPS-based payment adjustments will not take effect until 2019, and it is hoped that any compensation that may be introduced would be based on the data reported in 2017. However, healthcare providers are yet offered with another option. They can participate either fully or partially in any of the given Alternative Payment Models (APM). Meanwhile, all the eligible professionals and physicians will be exempted from any types of percentage revenue collected by APMs on the basis of MIPS.
There will be criteria that the APMs have to approve as part of the proposed rule that is being awaited. Reports indicate that some of the rules are yet to be developed into full format. Despite the existence of APMs in the form of Accountable Care Organizations (ACOs), there is a push from the side of MACRA to formulate new types of APMs. MACRA emphasizes that these APMs should be under the leadership of physician-led organizations.
The APMs that are being led by the eligible professionals and physicians have different responsibilities to hand over. While their primary responsibility is to avoid MIPS, other responsibilities that they have to handle include securing a minimum of 5% bonus payment from the Medicare. The bonus collected this way will be used to finance them in participating in APMs. Through this approach, they would become eligible for reimbursement, which would in turn safeguard them from any higher-level risk. Nevertheless, they still have to face nominal level risk factors, and the proposed rule warns these APMs to be prepared against them.
The subcommittee that was held in early March, under the leadership of House Energy and Commerce Committee, on the topic of health, heard all the suggestions of implementations proposed by MACRA. Many prominent personalities participated in the subcommittee. Patrick Conway, who currently serves as the Acting Principal Deputy Administrator for Innovation and Quality, represented CMS in the subcommittee.
Conway said that the presently laid bar seemed too high for the APMs to qualify for the nominal level. He said this when he was asked whether CMS had any plans to reconsider the nominal risk factor. He also suggested that there were few APM models, which stood closure to meeting the existing requirements. As of now, more than 55% of the eligible professionals and physicians take part in the APM programs.