After months of proposals, public comments, tweaks, and speculation, we now have confirmation of when and how MACRA will unfold. On October 14, CMS released the final rule for MACRA, Medicare’s most dramatic step away from volume-based reimbursement and toward value-based payments for physician services. The countdown to prepare has begun, with the start of the first performance period just over two months away.
Preparing for MACRA can seem daunting, but for the majority of practices that will be on the MIPS track, there are practical actions related to data collection and submission that your clinic can initiate now in order to be ready to meet the legislation’s requirements in 2017.
By failing to prepare, you are preparing to fail.
Select your practice’s quality measurements.
Of the four performance categories that make up the Composite Performance Score (CPS) in the MIPS track – that is, the score that determines whether your practice will be subject to a positive, negative, or neutral payment adjustment – the Quality Performance category has the single largest weight, accounting for 60% of the total CPS in 2019. In addition, Quality Performance is the category that will likely require the most time and effort, since many clinics are behind in defining, monitoring, and reporting on quality metrics.
In reviewing, analyzing, and selecting your practice’s quality measurements, consider using a system that scores each potential measurement based on a number of practical criteria, including:
- The number of beneficiaries in each measurement, since clinics are required to report on at least 90% of all patients from all payors and 50% of Medicare patients who meet the quality measurement’s denominator criteria. Having a larger pool of patients could lessen the impact of outliers.
- The ability to collect the required data for each measurement.
- Your practice’s ability to outperform its current performance, given that the score is in part based on the ability to improve over time.
Audit your practice’s ability to submit data.
Aside from the significant effort required in selecting and monitoring performance measurements, determine exactly how your clinic will submit the required data to CMS. Of the four performance categories, only the Cost category does not require any separate data submission, since that category’s data would be sourced and calculated from administrative claims data that is already submitted to CMS for reimbursement.
With regard to the remaining three performance categories, providers have multiple mechanisms for submitting data, including Medicare Part B claims, qualified clinical data registry (QCDR), qualified registry, and EHR. However, CMS has proposed certain restrictions to using these mechanisms; most notably, clinicians must use the same mechanism per category. To quote the rule: “a MIPS eligible clinician could use one submission mechanism for sending quality measures and another for sending improvement activities data, but…could not use two submission mechanisms for a single performance category such as submitting three quality measures via claims and three quality measures via registry.” CMS has also stated that in future years, it may even require all data in all categories to be submitted using a single mechanism.
Given this operational constraint, it is important to audit your practice’s ability to submit data for each of the proposed data submission mechanisms, considering important factors such as:
- The mechanisms already in place (especially if in the past, your practice participated in Medicare reporting programs that MIPS is replacing).
- Whether any modifications/upgrades may be required.
- The cost of any changes.
- The ability to submit using the same mechanism for each measurement in each category.
Doing this well ahead of the data submission deadline will provide ample time to make any changes and avoid unnecessary surprises.
Prepare a data submission plan.
March 31 of each calendar year is the submission deadline for all MACRA data, which means providers have eight weeks to collect, revise, and submit data from the close of the yearly performance period on January 1.
That’s a tight time frame. And while assessing your clinic’s ability to submit data in advance will give you a head start, it does not negate the important planning needed for the data submission period.
- Carefully consider your clinic’s logistics in submitting data, including who will be responsible for submitting it.
- Factor in possible additional administrative staff time to submit data, as well as any training or educational requirements needed for your staff to do so.
- Hold a mock data submission so that you can uncover any issues well ahead of the March 31 deadline.
And of course, the earlier the better – the last thing clinicians want is to uncover serious barriers to data submission weeks or even days before the deadline.
Preparing for MACRA is no easy task, but by taking some of the initial, practical steps as noted above, you can prepare with a degree of confidence in meeting MACRA’s plethora of rules and stipulations.