A 5 Minute Brief On The MACRA 2018 Proposed Rule

    Only three days ago, CMS released the much anticipated proposed changes to MACRA, after expectation that the Trump Administration would put its mark on value-based payment implementation efforts. It’s another doozy at 1,052 pages, so let’s dive right into what it’s all about and who will be affected. 

    What's the new proposed rule? Exemption for many (CMS believes a little over 130,000) small providers participating in MIPS by increasing their low-volume threshold to $90,000 or less in Medicare Part B charges or 200 or less Medicare patients annually. 

    Why was it released? Basically, CMS is showing their flexibility by conceding to the needs of physicians around the country. Giving them more time to prepare for reporting will hopefully reduce administrative burden – especially to those small practices – and allow them more time to focus on their patients. There has been a lot of clinician concern around spending too much time filling out paperwork instead of concentrating on caring for their patients (Which is a shame, since MACRA was created for Value-Based Care). However, the American Medical Association’s President David Barbe said it best: “"Not all physicians and their practices were ready to make the leap, and many faced daunting challenges. This flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country.”

    There are other added benefits. A lot, actually. CMS is really making an effort to make reporting easier for practices of all types. 
  • Physicians will be able to participate in MIPS through Virtual Groups, giving them the opportunity to work with other small practices and combine their administrative costs. 
  • Continuation of the "pick your pace" option for implementation of MIPS data reporting in 2018. 
    Continuing to allow the use of 2014-edition Certified Electronic Health Record Technology.
  • Small practices can receive extra bonus points within the Composite Performance Score for MIPS to recognize their value to communities where they practice. 
  • Adding the option for physicians to use facility-based scoring for facility-based clinicians such as hospitalists.
  • For physicians at small practices, adding a new hardship exemption for the advancing care information data-reporting category.

Optimism is high. CMS previously predicted that approximately 13% of solo physicians and 30% of small practices (2-9 physicians) would receive a positive payment adjustment under MIPS. With added flexibility by the proposed rule, it’s now predicted that 80% of small practices will receive a positive or neutral payment adjustment. 

Not out of the woods yet. The proposed rule eases the burden of reporting requirements significantly, but small practices still face challenges. Christopher Stanley, director at Navigant, said, “Readiness will still require investment in technology such as healthcare IT, people such as care coordinators and data support, and process such as establishing a Virtual Group. The proposed rule does not give a pass to rural providers—it simply opens the door that they will still need to walk through." 

So, what now? This is an opportunity for smaller practices to take time preparing. Don’t forget, the deadline for submitting public comments on the proposed rule is August 18, 2017. The Final Rule is expected to be released in the fall! 

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