2017 Trends: Nailing down MACRA
While the pins and needles feeling may have lessened slightly after the highly-anticipated release of the final rule on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), there’s still great anticipation in large role health information technology will play.
Health IT companies have a huge opportunity to step up to the plate like never before in advancing information sharing, improving quality care, and ensuring their provider customer base gains access to all important incentives-based Medicare payments under the new structure. To put it bluntly, HIT will be the tipping point to MACRA’s future.
CliffsNotes for your proficiency in “MACRA-ology”
First, it’s important to first understand MACRA’s final rule and implications. If you haven’t yet sorted through the final rule – yes, it’s a 2,400-page document – here are the “CliffsNotes” to study up on the complex course of “MACRA-ology:”
From Volume to Value
With MACRA, Medicare payment adjustments shift from the despised Sustainable Growth Rate formula to the Quality Payment Program (QPP). The QPP has two tracks that providers can choose from, including the Merit-Based Incentive Payment System (MIPS) or the Advanced Alternative Payment Model (APM).
By participating in an Advanced APM in 2017 and beyond, such as a Medicare Shared Savings Program Track Two or Three, providers earn more (a five percent incentive payment in 2019) for taking on some risk for their patients’ outcomes. With MIPS, providers earn a payment adjustment based on providing high quality, efficient care supported by technology by sending in information in these four categories: Quality, Improvement Activities, Advancing Care Information, and Cost – although data on cost will be calculated, it won’t factor into payment adjustments in the first year.
Goodbye Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM)
These programs sunset under MACRA and are wrapped into MIPS. The Quality category replaces PQRS, Advancing Care Information replaces the Medicare EHR Incentive Program, known as Meaningful Use, and the Cost category replaces Value Based Modifier.
2017 Is A “Warm Up”
Considered a transitional year, CMS’ aim in 2017 is simplicity and flexibility to help providers in the MIPS track “pick their pace” and prepare for long-term change.
For those who are ready to submit a full year of 2017 data to Medicare, they will earn a moderate payment adjustment in 2019, while others can just dip their toes in the water. The “partial” option allows for reporting 90 days of 2017 data for a neutral or small payment adjustment, while those who choose the “test” option only have to submit the minimum amount of data – just one quality measure or improvement activity for any point in 2017 – to avoid a downward adjustment in 2019. Those who don’t send any data at all for 2017 will receive a negative four percent adjustment to their 2019 payment. It is important to note that while 2017 is a low-risk “warm up” year, the risk for providers becomes greater in the following years as the MIPS track will become increasingly competitive for the pool of dollars.
HIT for Interoperability
CMS ended up with just five required HIT measures, in the final rule, rather than the 11 measures that had been proposed. Although, there are some additional optional measures, like utilizing certified EHR technology, which will award extra credit. The final five measures that CMS said are “focused on interoperability” and made the cut are: Security Risk Analysis; e-Prescribing; Provide Patient Access; Send Summary of Care; and Request/Accept Summary of Care.
So with a base knowledge of MACRA, QPP, MIPS, and advanced APMs – and more healthcare alphabet soup – what are the key implications for HIT companies who support providers facing all of these changes? CMS Acting Administrator Andy Slavitt has been pretty pointed in stating these companies will need to get their systems ready for prime time while opening the flow of information and ensuring their systems truly help physicians do their jobs better. Those who “compete” in this arena should be the big winners in the highly competitive space of EHRs, data analytics, and population health.
“If the HITECH Act allowed big EHR companies to form and grow, MACRA is the next shift and arguably a much richer opportunity,” Slavitt said when the final rule was released on Oct. 14. “Tech companies will compete to simplify and support the lives and jobs of physicians so they can be more productive, communicate better with their patients and other physicians, and have the information they need in their own workflow so they can succeed at value-based care, which is really the promise of MACRA.”
Strong Expectations for HIT Vendors
- Most providers are likely using 2014-certifed EHR technologies. Beginning in 2018, those physicians in the QPP must use technology that is certified for 2015.
- Third-party vendors must help alleviate some of MACRA’s reporting burden as CMS allows them to submit data for MIPS on behalf of clinicians.
- The ONC’s 2015 Edition Health IT Certification Criteria requires vendors to publish application programming interfaces (APIs) so software programs can talk to each other. The ecosystem has to be opened and apps developed to allow for seamless transfer of information, especially between EHRs.
Win Big as a MACRA Thought Leader: Three Considerations
As providers sort through implications of the final rule and “pick their pace” for 2017, they can benefit from someone who can help them navigate the MACRA path ahead. Companies that serve as MACRA thought leaders for their customers and prospects are likely to reap great rewards.
- Educate – A Physicians Foundation survey found that only 20 percent of physicians are familiar with MACRA. Meanwhile, 56 percent of physicians said they were either “somewhat unfamiliar” or “very unfamiliar” with MACRA. Before providers can engage or be convinced to perform better, they have to understand what’s at stake. HIT companies should be first educating their customers about MACRA, followed by helping them understand the value in this transition before they can layer on, or even sell, HIT systems and tools.
- Optimize for quality– Many providers hastily put EHR platforms into place as part of meeting MU requirements. Most have yet to fully optimize the systems for their various, unique care environments in a way that supports physician and nurse thinking, complex workflows, and outcomes. There’s so much more opportunity than just having these HIT systems in place – specifically, helping customers optimize them for usability, which may require additional apps and add-ons, to achieve better outcomes that will result in the highest possible MACRA payment incentives.
- Offer a unique point of view – What’s your company’s unique take on MACRA? Determine your unique point of view on the road ahead that plays to your prospects’ and customers’ biggest challenges and needs.
Looking for more resources?
The American Hospital Association has a MACRA resource to help your system transition and toolkits for community leaders, hospital staff and board members.