Looking Forward to Release of MACRA Final Rule—More Details about “Pick Your Pace” and Much More

Right now, the Final Rule to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is under its last level of review in the White House Office of Management and Budget (OMB) before it is released to the public. It’s really anyone’s guess when the Quality Payment Program’s (QPP’s) Final Rule will be released, but we expect that it will be in the next few weeks.  As the MACRA NPRM garnered nearly 4,000 public comments, all healthcare stakeholders are eagerly awaiting its publication.  Me included.

Payment Model Transformation: It’s difficult to overemphasize the importance of this rule to healthcare transformation efforts across the community. Since early in 2015, the Obama Administration has been working toward new goals for transforming Medicare by moving away from traditional fee-for-service payments in Medicare toward a payment system focused on linking physician reimbursements to quality care through alternative payment models (APMs).  This effort is part of an overarching Administration strategy to transform how healthcare is delivered in America, changing payment structures to improve quality and patient outcomes. 

More on MACRA: MACRA gets to the heart of these efforts as the latest manifestation of the Administration’s reform plans. Along with the successful coverage expansions and improvements to access under the Affordable Care Act, it is intended to support the nation’s progress toward achieving a patient-centered healthcare system that delivers better care, smarter spending, and healthier people and communities—all such worthwhile aspirations. 

The fever pitch around the contents of the Final Rule reached a crescendo two weeks ago when Centers for Medicare & Medicaid Services (CMS) Acting Administrator Andy Slavitt’s blog post announced CMS’s intention to change the performance timeline for the first year of QPP in 2017. 

HIMSS Comments on MACRA: Many entities (including HIMSS) used their MACRA public comments to discuss how challenging it would be to meet QPP requirements for a full 365-day performance period in calendar year 2017, when the Final Rule was not going to be released until 60-90 days before what was intended as the start of the first performance year. Slavitt presented four options for clinicians, and although specific details are still a bit sketchy, it suffices to say that clinicians will have flexibility to meet requirements in 2017, as well as avoid a negative payment adjustment, and possibly qualify for a positive payment adjustment. 

I think that “pick your pace of participation” is the right approach for CMS to take here—clinicians that are ready to implement QPP for a full-year can proceed as scheduled, while those that need a little more time, get that time, and are not penalized for their longer implementation timeline.  This policy pushes payment reform efforts forward, but also insulates those that not quite prepared yet. 

The other critical dynamic in play are the educational efforts that CMS is supporting to ensure that clinicians in small practices have the information and resources they need to fully implement QPP.  These are the clinicians that are generally the most under-resourced and need the most help to carry out significant programmatic changes. 

Provision for Small Practices: The MACRA Law included a provision for $100 million ($20 million per year for five years) to help small practices successfully participate in QPP.  CMS is in the process of awarding contracts to organizations to provide QPP technical assistance targeting eligible clinicians in individual or small group practices of 15 or fewer, focusing on those practicing in historically under resourced areas, including rural areas, health professional shortage areas, and medically underserved areas.  The organizations that receive these awards will have to hit the ground running and begin to assist practices later this year, so here’s hoping that the awards are made ASAP. 

HIMSS MACRA Resource Center: HIMSS also has a role here and is working to provide additional resources to stakeholders and the community at large.  I regularly point folks to the HIMSS MACRA Resource Center for details on the Quality Payment Program (QPP), Merit-Based Incentive Payment System (MIPS), and alternative payment models (APMs).  When the Final Rule is released, we will post essential information to the HIMSS website, update our fact sheets, and ensure that our offerings satisfy the needs of our members. 

Are you prepared to implement QPP?  Feel free to reach out to me with questions, comments, or additional resources that are needed.  Let’s get QPP implementation underway and make more progress toward transforming healthcare!