REGULATORY REVIEW


MACRA Is Here What you need to know about the new Medicare clinician payment system BY ALEX TAIRA


In last year’s November- December Focus mag- azine we outlined the Medicare Access and CHIP Reauthorization


Act, com monly known as MACRA. This act, passed in 2015, instituted new mechanisms for Medicare physi- cian payment, replacing the old Sus- tainable Growth Rate (SGR) formula. With the arrival of a new administra- tion, as well as the June release of pro- posed updates, it seems worthwhile to reiterate MACRA’s overarching struc- ture, highlight some new develop- ments and give an indication of how it might affect clinicians operating in ASCs in the coming years. From 1997 to 2015 Medicare phy- sician payments were determined by the SGR, a formula that tied year-to- year payment updates to economic growth. The formula was widely rec- ognized as deeply flawed, requiring yearly congressional action to stave off physician pay rate cuts. Growing calls for reform coincided with larger shifts in prevailing health care policy, namely the desire to move away from fee-for-service (FFS) based reim- bursement as well as increased usage of health care information technol- ogy (HIT). MACRA was ushered into law with wide, bipartisan sup- port, setting the groundwork for tran- sitioning to a value-based purchasing system beginning in 2017. MACRA’s new payment structure


is called the Quality Payment Program (QPP). It is worth noting right from the beginning that this system does not concern ASC facility payments in any way, only those physician ser- vices reimbursed by Medicare. The QPP splits Medicare physicians into two payment paths: the Merit-Based Incentive Payment System (MIPS)


The new administra- tion has signaled a desire to slow down implementation of MACRA/QPP, giving physicians time and flexibility to ease into the structure of the new system and get used to a new reporting framework."


—Alex Taira, ASCA


and Advanced Alternative Payment Models (APMs). Advanced APMs are unique care models such as bundled episodes of care, comprehensive care models, and accountable care organi- zations (ACO). Most physicians who practice in ASCs will not be eligible for any of the Advanced APMs, at least for now. Most ASC physicians will have to comply with MIPS requirements, how- ever. Proposed updates released in June of this year would expand exemptions from MIPS to any physician with up


Track the Latest Regulatory and Legislative News for ASCs


Visit ASCA’s web site every week to stay up to date on the latest government affairs news affecting the ASC industry. Every week, ASCA’s Government Affairs Update newsletter is posted online for ASCA members to read. The weekly newsletter tracks and analyzes the latest legislative and regulatory developments concerning ASCs.


www.ascassociation.org/ GovtAffairsUpdate


20 ASC FOCUS SEPTEMBER 2017 |www.ascfocus.org


to $90,000 per year in Medicare Part B charges or who serves fewer than 200 unique Medicare patients. Though they have not yet been finalized, these prospective limits are significantly expanded from the 2017 final rule which exempted those below $30,000 in charges or 100 unique patients. If you are a clinician who is unsure about your MIPS reporting responsibilities, you can visit qpp.cms.gov to access a tool that allows you to check MIPS participation through your national provider identifier (NPI) number. CMS expects that most physicians will start reporting in the MIPS program and transition to the Advanced APMs track over time.


The MIPS program will phase in


over the next five years, with 2022 being the first year in which physi- cians will be eligible for a maximum 9 percent payment adjustment, up or down. The “reporting period,” or time during which a physician would col- lect data for MIPS reporting, is the calendar year. Physicians would then submit any data collected and receive a payment adjustment in a subsequent year. For example, physicians are eli- gible to begin collecting MIPS data in the 2017 reporting period, January to December 2017. Any performance data must be submitted to CMS by March 31, 2018, and CMS will then calculate a commensurate payment adjustment, up or down, for the 2019 calendar year. The timeline can seem confusing and onerous, but one main takeaway is that the extent of a phy- sician’s MIPS participation this year can have effects years down the road. Thus, as we get into what performance categories MIPS encompasses, physi- cians would be prudent to consider their ability to submit such data.


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