MACRA and MIPS: They Promised Simpler!

open-book-formulaThe proposed MACRA rule is here. With the goal of changing the way physicians are paid, this rule proposes how CMS intends to move toward increasingly rewarding value—meaning high quality care at a cost-effective price—over volume.

CMS claims that MACRA will simplify life for providers, (although I’m a little suspicious since it took 962 pages to explain the “simplification”). However, there is no question that the world is about to change. These proposed regs are scheduled to be finalized in November and then be effective on January 1, 2017—a rather ambitious schedule which leaves little time for planning your approach to compliance.

While I haven’t read the entire rule yet, MACRA—Medicare Access and Chip Reauthorization Act—provides two paths for physicians and other clinicians. In the long-term, APMs (Alternate Payment Models, like ACOs) will be a popular route—higher risk/higher reward—but for now, most physicians will participate in the MIPS (Merit-Based Incentive Program) option. So let me provide a few teasers about MIPS, as currently proposed:

  • If you expected an end to Meaningful Use, PQRS, and the Value-Based Payment Program, you will be disappointed for certain. MIPS just changes the names, rolls them up into one program, and adds (yet another) set of required activities.
  • Providers will be scored on a 100-point scale and compared to other providers—this year’s weighting would be 25% MU-type measures, 50% quality measures, a la PQRS, 10% cost, and 15% Clinical Practice Improvement Activities. (The rule spells out how a provider’s score is calculated and the payment adjustment is determined, but you might need an advanced math degree to follow that discussion!)
  • MU is now “Advancing Care Information”. It will have fewer required measures (proposing to eliminate CPOE, CDS, and multiple Public Health reporting requirements), no longer be all or nothing, and will provide some choices to clinicians for how they demonstrate success. CQM reporting will not be part of this component.
  • Quality measure reporting (like PQRS) will be the bulk of the score, but only 6 measures will be required. Like under the Value-Based Payment Program, performance will count, i.e., impact the provider’s score.
  • Assessment of cost will be done by CMS—providers won’t have to report anything. This is similar to how CMS currently attributes a cost factor to providers in calculating the V-BPM.
  • The new category, Clinical Practice Improvement Activities, offers providers a choice of approximately 90 activities from which to choose to earn points in that category.
  • MIPS would be reportable as an individual provider or as a group.

Stay tuned to EMR StraightTalk for more in-depth analysis of MACRA in upcoming posts. We welcome your initial comments.

 

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

4 thoughts on “MACRA and MIPS: They Promised Simpler!

  1. Nightmare. Total nightmare. Should have guessed it was going to be bad but MACRA is the most complex regulatory scheme(s) I have ever put my eyes on. Changing names and slugging us with a baseball bat 11 times a day instead of 18 is somehow better? More of the same with PQRS now Quality to that slap if the face continues. But they added in a whole section of meaningless activity with Clinical Practice Improvement which is like beating us now with a shoe.When will this stop? All of MIPS is a Newtonian math contest to determine your penalty, so its a complete crap shoot if you are up 9 or down 9. Its like no one looked at the big picture, just a bunch of policy wonks working feverishly to write a 1000 page ridiculoma. Add in AAPM’s which no one on this earth could figure out without a team of lawyers, accountants and policy advisors, that is just a non-starter. When John Halamka says ” As a practicing clinician for 30 years, I can honestly say that it’s time to leave the profession if we stay on the current trajectory.” I think that was a shot across the bow of ONC and CMS. Might have shook them up a bit. Its high time that ONC and CMS drop all EHR certification and let vendors work on innovation, customization, and directly with physicians. Its high time we let doctors be doctors again, or the damage will be devastating and irreversible. They were worried about losing the hearts and minds of physicians, I dare they that have lost us forever.

  2. We understand your frustration with these changes and complexities. It is one of the reasons we put so much focus on proactively helping our clients navigate these tricky waters. This will become even more important as we experience the changes inherent in moving from a volume to value-based payment world.

  3. I appreciate your blog and letting me vent, but if you read the comments on the proposed MACRA rule, you will not see very many positive ones, pretty much 99% negative. This whole puffery language of “value-based” and silly terms are ill-defined and just not proven to be any better, if not worse than the “FFS” or “Volume” based world. Squeezing providers and inundating us with complex regulatory schemes will only backfire the “Value-based” ideal. If Meaningful Use and Health IT was so worth it and great, after 35 billion, we would see some reduced costs, improved care and or increased satisfaction…right? I hardly think so. So before we embark on more of the same with MACRA and beating us to death with silly terms and new programs, we should look to see what works, before we penalize hard working front line physicians just trying to care for patients in this complex world. Its ok if they want to bonus those that want to experiment, but dont penalize the rest of us.

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