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MACRA Implementation

CMS just let out a Proposed Rule on the implementation of MACRA, a few days after the one-year anniversary of the Act itself being passed. The rule lays out methods the agency intends to use for implementing MIPS and APM, which together will replace the SGR. MACRA is the main legislation behind the removal of SGR, which also leaves a broad framework for the way the aforementioned reimbursement systems will work. Rulemaking is left to the discretion of CMS.

This rule lays out the criteria, definitions and other specific details necessary for implementing MIPS and APMs. CMS will set up a hearing of what stakeholders think before it puts out the final rule this year. MIPS brings together and distills the current CMS quality measurement programs, which are the PQRS, the Value-based Modifier, and MU.

There will be a single “Composite Performance Score” (CPS) assigned to providers to show the quality of their performance, cost cutting, and use of resources. This score will allow them to get a reimbursement adjustment, whether positive or negative.

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The 2017 calendar year is being proposed as the first reporting year at this point, so that 2019 becomes the year for the first payment adjustments. There will be a four percent adjustment then, although the figure could go up to nine percent by year 2022, remaining at that level subsequently. Adjustments by MIPS are budget neutral, which means the total amount of bonus payments should come up to the total payment reductions. In 2019, CMS will make an estimated payout of $833 million as MIPS bonus, with an equal penalty amount offsetting that. Providers with adjustments will number between 687,000 and 746,000.

MACRA also includes an additional $500 million that falls under performance bonuses not subject to the requirement of budget neutrality. For context, CMS only projects around 30,658 to 90,000 eligible providers qualifying for MIPS exemption through APM participation. For the year 2019, the agency estimates APM incentive payouts between $146 million and $429 million. The new systems are meant to boost quality, cut costs, and make optimize the use of resources.

In 2019, quality will become the single most vital part (50 percent) of the MIPS score for providers, with EHR use and Health IT making up 25 percent besides that. Clinical practice improvement will figure 15 percent of the score.

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