From the Washington Office

Release of the MACRA Final Rule


 

On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released the final rule pertaining to the Medicare Access and CHIP Reauthorization Act (MACRA). As I write, almost three weeks later, Division of Advocacy and Health Policy staff are generally pleased with the contents of the rule as there were no big “negative” surprises and stakeholder input in response to the proposed rule seems to have been broadly taken to heart by the administration at CMS.

As Fellows prepare for 2017, they should take note of several changes that were made to the original proposed rule. Some key changes are summarized below.

Dr. Patrick V. Bailey

Dr. Patrick V. Bailey

In an obvious response to concerns expressed by stakeholders, CMS will not include an assessment for Resource Use when calculating provider Composite Performance Scores in the first year of the program, 2017. Regular readers of this column will remember that in the proposed rule, Resource Use was to have comprised 10% of the Composite Performance Score in 2017. Because MACRA requires the Quality and Resource Use components together must comprise a total of 60% of the Composite Score, in 2017, the Quality component will account for the entire 60%. CMS still plans to collect the data it planned to utilize to assess the Resource Use component but again, will not use such to make assessment relative to individual surgeons’ Composite Performance Score.

With regard to what was previously referred to as the Clinical Practice Improvement Activities (CPIA), the nomenclature as well as the associated requirement have been shortened and simplified. Now called simply Improvement Activities, to achieve full credit most physicians will need to report on between two to four of the nearly 100 possible activities as opposed to up to the six activities needed to meet the requirements as outlined in the proposed rule. Fortunately, the reporting requirement for the Improvement Activities component remains the simple attestation that one has participated in the selected activities for a period of 90 continuous days during the 2017 reporting period. Improvement Activities continues to comprise 15% of the Composite Score.

With release of the final rule, we now have a more concrete definition of what CMS Acting Administrator Andrew Slavitt meant by “Pick Your Pace” which was the topic of last month’s column (October 2016, p. 15). CMS is looking at the 2017 reporting period as a transition year with which it hopes to engage physicians in participation in its new Medicare physician payment plan. As such, surgeons and other physicians will NOT receive a negative assessment on their 2019 Medicare payment if they simply report on one Quality measure for 90 days, OR one Improvement Activity for 90 days (again by simple attestation) OR four required Advancing Care Information measures utilizing a certified electronic health record (EHR). Accordingly, it is entirely possible for ALL to avoid the 4% penalty prescribed for those who report nothing for 2017.

ACS has developed numerous resources to assist surgeons in preparing for the 2017 reporting period. In addition to articles published in ACS Surgery News and other ACS publications, a website has been launched at www.facs.org/qpp. The website contains a series of videos based on the requirements outlined in the proposed rule, downloadable Power Point presentations, a glossary of terms and acronyms and perhaps, most importantly, a list of activities that surgeons can undertake now in order to best prepare themselves for the changes outlined in the final rule for January 2017.

In the coming weeks, plans are in place to revise the slide presentations and videos to reflect the modifications of requirements found in the final rule, publish a series of fact sheets designed for surgeons in various practice circumstances (employed surgeons, private practice surgeons, surgeons in small and/or rural practice, surgeons in large group practice), revise and republish the booklet entitled Resources for the New Medicare Physician Payment System, first made available to attendees at Clinical Congress in Washington in October, as well as the recording of an instructional webinar.

Based on the requirements outlined in the MACRA final rule, I am very confident that with minimal effort surgeons will be able to avoid a negative payment adjustment in 2019 based on their performance in the 2017 reporting period. Further, for those surgeons who are already participating in quality reporting and/or are well familiar with the requirements of the electronic health record program, it is entirely possible they will receive a positive update. ACS staff continue to endeavor to provide resources to Fellows to ensure their success.

Until next month…

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