CMS has given provider organizations a major reprieve by phasing in MACRA’s provisions more incrementally than originally anticipated. Providers should respond not by postponing their preparations for MACRA, but by focusing now on optimizing their performance over the long haul. It is not too late to create a bridge strategy that will avert a penalty and potentially result in a small positive payment adjustment during this transitional period. A longer-term strategy will prove essential as MACRA’s temporary protections are phased out and providers experience significant payment risk based on their performance.
Provider organizations need to undergo a thoughtful planning process that addresses the following questions:
- Which MIPS measures (for quality, EHR use and clinical practice improvement activities) are most relevant to our patients?
- Which ones can we manage effectively given our provider mix, culture, leadership/governance capabilities, IT infrastructure and care management processes? What competencies must we develop in order to produce results?
- How should we report data to CMS? As individuals, groups or multiple tax IDs? Through which reporting mechanisms should we submit our data?
- Is MIPS going to be our long-term strategy, or should we be considering a transition to APM reimbursement? What are the financial, operational and organizational implications of these options?
While the immediate payoff for this work may be small, the real benefit will be realized over time. Those who make it a priority to develop their strategy now will be glad they did so in the not-too-distant future.
Previously appeared in the August 2017 issue of Accountable Care News.