MACRA 2018 Proposed Rule: It’s Here

June 21, 2017 · Amy Maciejowski

The Centers for Medicare and Medicaid Services released the MACRA 2018 proposed rule late Tuesday. While most still ride the current wave of MACRA requirements for this year’s reporting- it’s already time to look towards 2018.

Our team quickly scoured the lengthy document to provide you a quick and easy summary.

One thing is clear: the proposed rule continues the gradual pace of MACRA implementation and provides new provisions that help small and rural practices.

Our First Takeaways

At NCQA, we recognize exceptional practices that keep patients at the center of care. And, CMS continues to acknowledge that. We are pleased that another one of our recognition programs is called out in the Improvement Activities category. The 2018 proposed rule includes our Patient-Centered Connected Care™ program as an “improvement activity” in MIPS. This means NCQA-Recognized practices will be able to count this towards their MIPS score for that category. (Our PCMH and PCSP practices are already given credit for this category.)

We welcome the benefits MACRA delivers for recognized practices that deliver quality care.

As we’ve mentioned in our last blog on virtual groups, the virtual groups revision will allow small and rural practices to work together, collaborate, share financial risk and work towards a shared goal. Small and rural practices can use virtual groups as an opportunity to increase their chance of a higher MIPS score. Also, they can use this as a stepping stone to join an APM in the future.

A suggestion, CMS needs to do one more thing to improve on virtual groups: provide bonus points. Joining a virtual group is not without its challenges. It’ll take some leg work and a lot of coordination. To encourage clinicians to join them, CMS should offer bonus points.

A Summary

In the proposed rule, CMS:

• Estimates that a very small number of doctors are expected to end up on the penalty side of the equation in MIPS. (Roughly 6% of all MIPS eligible clinicians and >20% of those in practices of 15 or less).
  • Of course, in MACRA’s revenue-neutral equation for MIPS, that means bonuses will also be limited.
• Protects small and rural practices from penalties. The proposed rule includes some protections for these practices, including:
  • Practices can band together and form a “Virtual Group.” Read more here.
  • The Part B revenue threshold for clinicians exempt from MIPS was tripled. The patient threshold was doubled. So, it exempts practices with less than $90,000 in Medicare Part B charges or fewer than 200 Medicare patients.
  • Small and rural practices that can demonstrate a “significant hardship” are exempt from the advancing care information performance category.
• Expands existing and adds new Advanced Alternative Payment Models (APM).
  • With that- even more practices are expected to qualify for the APM track in 2018 to potentially be eligible for 5% bonuses. CMS expects 180-245,000 clinicians will be APM-qualified (vs. 70-120,000 in 2017).
  • The Advanced APMs added for 2018 include:
    • Advancing Care Coordination Through Episode Payment Models: Track 1 CEHRT
    • Vermont All-Payer ACO Initiative (Medicare)
    • Medicare Shared Savings Program: Track 1+
• Allows practices to use the 2014 edition of Certified Electronic Health Record Technology (CEHRT) in 2018. However, practices willing to take the extra step and use the 2015 standards will receive bonus points.
• Keeps the “cost” category in MIPS at 0% for 2018.
• Increases number of PCMH and PCSP practices that need to be recognized under a given Tax Identification Number (TIN). In 2018, the proposed standards require 50% of practice sites within a TIN must be recognized. (In 2017- the rule said only one practice within a TIN needed to be a PCMH or PCSP).

There’s More to Read, So Stay Tuned!

So, that’s our summary of proposed updates to MACRA for 2018. As we continue to read, we want to know your initial reactions to the proposed rule. Do you see the changes as helpful? What do you think? Comment below.

We will be sending our thoughts to CMS, you should too.