MACRA Matters Affecting Rural Providers

Think of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as a 1,500-piece jigsaw puzzle, or a pathway to success in tying payments to value. Every piece of the puzzle is integral to strategic planning and sustainable mapping, but until the pieces are aligned, they can’t create an accurate picture of the future. 

So, how does the puzzle look today for rural health? Let’s move from the previous storyline of Centers for Medicare & Medicaid Services (CMS) recommendations for rural providers to the current realities for those providers, and then continue with an update on the CPC (Comprehensive Primary Care Plus) Plan and whether that means anything for them.

What Size Do MACRA and Rural Healthcare Fit Into?

MACRA isn’t one size fits all; it has a different impact, meaning, implications, and results depending on provider structure – whether you’re talking about an urban or rural health system, an independent or small practice, critical access hospitals (CAHs), rural health clinics (RHCs), or federally qualified health centers (FQHCs). 

• Some providers won’t face any pressure in the near future to attain a high Merit-Based Incentive Payment System (MIPS) score, because they just won’t be required to do so. The exclusions in the MIPS attestation process include clinicians newly enrolled in Medicare, QPS-qualifying alternative payment model (APM) participants, certain partial qualifying APM participants, and those providers that practice with a low-volume threshold. 
• As it relates to CAHs, RHCs, and FQHCs, CMS has proposed that services provided at these entities meet a type of criteria to be counted towards qualifying APM professional determination.
• Due to how these entities are paid under Medicare, RHCs and FQHCs are currently exempted from reporting to MIPS.
• Many CAHs and other rural hospitals might not participate in MIPS due to the low-volume threshold. Stay tuned, though – the final proposed rule for rural providers might have enhanced changes.