Issue link: https://viewer.e-digitaledition.com/i/727041
L A ST YE AR, THE Medicare Access and CHIP Reauthorization Act (MACR A) eliminated Medicare's SGR formula and required Medicare, beginning in 2019, to provide value-based reimbursement to physicians. MACR A represents a big step away from traditiona l Medicare fee-for-service. (In the meantime, the Medicare physician fee schedule will increase .5 percent annua lly). As you weigh your options for adapting to the MACRA changes, the following are some thoughts to bear in mind. Verify that MACR A applies to your practice. Certain payments and physi- cians are exempt: IPPS, OPPS, and ASC Payment System payments; physicians who fall under Medicare's low volume threshold ($10,000 or less in Medicare cha rges a nd 100 or fewer Medica re patients); and physicians in their first year billing Medicare. Determine which track of M ACR A applies to you: the Advanced Practice Model (APM) or Merit Based Incentive System (MIPS). If your practice pa r ticipates in a n APM, determine whether it is a quali- fied advanced APM, as such APMs are exempt from MIPS. An advanced APM has more than "nominal" financial risk to the participating physicians. Examples include Tracks 2 and 3 accountable care organizations (ACOs) (i.e., those with shared risk), next generation ACOs, the Oncology Care Model Two-Sided Risk A rra ngements, Comprehensive End Stage Renal Disease Care Models, and cer tain bundled payment initiatives. Track 1 ACOs and the Comprehensive Joint Replacement prog ra m a re not considered advanced APMs. Practices on the APM track will receive upfront, lump sum annual payments of 5 percent of their previous year's Medicare Part B payments in 2019 through 2024, with a higher fee schedule update to follow (as compared to the MIPS track). If your practice is not in an advanced APM — the majority of practices are not — then it will fall into the MIPS track. The MIPS model bases payment adjustments to the Medicare fee schedule on existing PQRS, value-based modifier, and mean- ingful use incentive arrangements. The adjustment amount will depend on each physician's overall composite score, scaled against a benchmark score established by CMS, and will range from -4 percent to 37 percent. Review the MIPS metric categories and assess the practice's ability to satisfy and report on the appropriate measures beginning in 2017. Implement corrective action as necessary. + Quality is 50 percent of the practice's total score in the first year of MACR A. CMS w i l l track popu lation-ba sed performance measures using claims information. Practices must report six measures including one outcome mea- sure and one cross-cutting measure. + Adva ncing Ca re Infor mation (for- merly Mea ning ful Use) is 25 percent of the score. Practices must repor t on eleven measures indicating day- to-day use of hea lthca re information technolog y, including interoperabil- it y a nd information excha nge. + C l i n i c a l P r a c t i c e I m p r o v e m e n t Activities is 15 percent of the score. T h i s cat egor y mea su re s pr a c t ic e a c c e s s , b enef ici a r y en ga gement , population hea lth ma nagement, a nd emergency prepa redness. Practices will have some f lexibility in choosing options; there will be over 90 options from nine categories. + Resource Use (formerly, va lue-based modif ier) is 10 percent of the score. There will be 40 additiona l measures based on episodes of ca re. This mea- sure w i l l look at cla ims data ; there is no practice repor ting obligation. Medica re ha s not yet f ina lized the M ACR A rules a nd is unlikely to do so until later this yea r (with 2017 remain- ing a s yea r one). The f ina l r u les may deviate sig nif ica ntly from the current pr op o s e d r u le s; pr a c t it ioner s ver y wel l may see additiona l g uida nce on these issues. Michael VanBuren is a Partner in the Health Care Practice G roup at Brouse McDowell in Akron, Ohio. ■ for MACRA BY MICHAEL VANBUREN A Checklist 2 9 M D N E W S . C O M /// M D N E W S C L E V E L A N D /A K R O N / C A N T O N n S E P T E M B E R / O C T O B E R 2 016 B U S I N E S S S E C T I O N 2 9