- New MACRA flexibilities for the first performance year of the program may help some providers ease into new value-based reimbursement programs, but the American Medical Group Association (AMGA) recently argued that new attestation tracks may unfairly financially penalize providers that have already prepared for the program.
Last week, CMS announced that eligible clinicians can choose between four flexible reporting tracks in the first performance year to ensure that all eligible clinicians have the opportunity to succeed under MACRA’s Quality Payment Program.
Three of the four reporting tracks, which expand the options for participating in the MIPS program, offer eligible clinicians different levels of data reporting.
The first option allows participants to test the Quality Payment Program with partial data reporting, which will allow them to avoid a negative payment adjustment.
Eligible clinicians can also elect to report to the value-based reimbursement program for either part of the 2017 calendar year and be eligible for a “small positive payment adjustment” or report data on the full calendar and qualify for a “modest positive payment adjustment.”
Participating providers can also select the fourth reporting option and fully participate in a CMS-approved Advanced Alternative Payment Model, such as Medicare Shared Savings Program Tracks Two and Three. If eligible clinicians maintain the Medicare payment and beneficiary volume thresholds, they would be eligible to earn a five percent incentive payment in 2019.
While AMGA acknowledged that some providers, especially those in small practices, may need more time and resources for MACRA implementation, the organization stated that many other eligible clinicians have the necessary reporting and logistical capabilities to fully participate in the Quality Payment Program on the scheduled go-live date.
Donald W. Fischer, PhD, CAE, AMGA President and CEO, said:
“[O]ur membership is deeply concerned that the creation of these new reporting options will have the unintended result of penalizing the very provider groups that have made the largest investments to meet MACRA’s goals of better quality, improved clinical practice activities, better use of electronic medical records, and lower resource use. These groups have already begun the transition from volume to value, and it is disappointing the rewards for their efforts will be compromised rather than rewarded, as was MACRA’s stated purpose by Congress and the Administration.”
To avoid potential financial penalties and modest payment adjustments, AMGA advised CMS to ensure that all eligible clinicians are evaluated for quality of care equally under the Quality Payment Program.
“We understand that the details related to the four options are not yet fully known and may change,” Fischer continued. “We ask that CMS continue to create a quality mechanism that assesses all providers equally and that the Congress afford physician stakeholders the appropriate public forums to respond to this new refinement as well as the overall MACRA implementation.”
Other healthcare industry groups have been more receptive of the MACRA flexibilities. The American Medical Association (AMA) commended CMS for listening to stakeholder concerns about the original timeline proposed for MACRA, and expressed support of flexible attestation tracks because they would give all types of providers an equal opportunity to succeed under new value-based reimbursement models.
“By adopting this thoughtful and flexible approach, the Administration is encouraging a successful transition to the new law by offering physicians options for participating in MACRA,” Andrew W. Gurman, MD, AMA President, said in a statement. “This approach better reflects the diversity of medical practices throughout the country.”
“The AMA believes the actions that the Administration announced today will help give physicians a fair shot in the first year of MACRA implementation,” Gurman added. “This is the flexibility that physicians were seeking all along, and we are looking forward to working with Acting Administrator Slavitt and the administration on other efforts to get MACRA off to a successful start.”
While CMS developed the MACRA flexibilities in response to shareholder feedback regarding small practices, it has not clarified how the attestation tracks will affect payment adjustments. The announcement stated that eligible clinicians who report to the Quality Payment Program in 2017 can avoid a negative payment adjustment or qualify for “small” and “modest” adjustments depending on the level of reporting.
For high-quality and cost-effective providers in the first performance year, eligible clinicians could earn a four percent payment increase under the Merit-Based Incentive Payment System (MIPS) in 2019, according to the proposed MACRA implementation rule. However, some organizations are concerned that providers who are prepared to attest to MIPS on the scheduled launch date may no longer be able to achieve the four percent adjustment.
Earlier this year, AMGA advised CMS to postpone the launch date of MACRA from January 1 to July 1, 2017 to give providers more time to implement resources needed for the program and ensure eligible providers understand the final rule, which is expected to be published sometime in November.
While CMS has not expressed any intention to delay the go-live date of the new value-based reimbursement program, it did intend for MACRA flexibilities to help eligible clinicians prepare for and succeed under the Quality Payment Program.