MACRA, MIPS, and APMs

With the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), CMS has proposed a Quality Measure Development Plan that will combine all of the existing quality reporting programs into one new system. To report quality measures, providers will participate in either the Merit-Based Incentive Payment System (MIPS) and/or Alternative Payment Models (APMs).

First, do you qualify?

If you have $10,000 or less in Medicare chargesand 100 or fewer Medicare patients annually, then you are exempt from MIPS participation. Otherwise, you need to participate in a MIPS or APM model.

MIPS

CMS anticipates most small practices will participate in MIPS. MIPS adjustments are budget neutral, and a scaling factor will be applied based on quality and cost measures to make total upward and downward adjustments equal. If you participate in MIPS, you will need to monitor the various components that are being combined to maximize your potential incentives:

1. Continue to attest for Meaningful Use

If you are already participating, continue to do so to take advantage of incentives and to avoid payment adjustment in 2018 (Medicare adjustments are made looking back 2 years). By 2017, the Medicare Meaningful Use Incentive program will transition into the Advancing Care Information (ACI) component of MIPS.

2. The Advancing Care Information (ACI) component will change several things about Meaningful Use measures:

• Meaningful Use will no longer be a standalone program. ACI will account for 25 percent of your MIPS score (100 points), the total of which will determine payment adjustments (maximum downward adjustment for Year 1 would be negative 4 percent, and the maximum upward adjustment is 12 percent).
• The "all or nothing" approach to Meaningful Use incentives has been abandoned in favor of scaling performance under ACI, so providers don't need to meet all of the goals. The scoring is split up into two categories: "Participating" and "Performance."
• Participating providers will receive 50 points of the total possible 100-point ACI category score. But to "participate," providers need to complete a security risk analysis, be in active engagement with an immunization registry (or qualify for an exclusion), and report a numerator (of at least one) and denominator for all remaining measures. If these baseline measures aren't provided, then the provider isn't participating and no points will be awarded.