An Early Look at MACRA for Hematology

An Early Look at the MACRA Proposed Rule

On Wednesday April 27, the Centers for Medicare and Medicaid Services (CMS) released their long-awaited proposed rule for implementing the Medicare Access and CHIP Reauthorization Act (MACRA), the law passed in April of 2015 that eliminated annual planned Medicare payment cuts for physicians, replacing it with a system with small predictable updates that are adjusted based on performance. The law also provided a mechanism for physicians to participate in payment models outside of the traditional fee-for-service system. Given the length and complexity of the rule, it will require some time to review and analyze. However, there are a few key takeaways from the an initial review. However, given this is a proposed rule, things could change significantly before 2017, when measurement will begin for payment adjustment that begins in 2019.

• Most physicians will not participate in alternative payment models

The legislation envisioned a path in which some physicians were able to participate in payment models such as accountable care organizations instead of the current fee-for-service system embellished with pay-for-performance. However, CMS has proposed to rather rigidly define an alternative payment model and has estimated that more than 90% of physicians will not participate in the first year.

• Quality Measurement Remains Paramount

While there are technical changes that are important, failure to report on quality measures will still have a deleterious effect on a pay-for-performance score under the new Merit-Based Incentive Payment System (MIPS). CMS proposes to reduce the number of measures required for reporting from nine to six in many circumstances. All of the mechanisms for reporting such as registries and electronic health records are proposed to still be available.

• Incentive for Electronic Health Record Use will be More Flexible

Incentives for the so-called “meaningful use” of electronic health records date back to the stimulus bill passed in the first days of the Obama administration. Since that time, an elaborate series of rules has differentiated health information technology, requiring certification for the technology and demonstration of certain uses of that technology by the physician practice. Over time, vendors have been unable to keep up with rapidly evolving certification standards that some believe do not reflect the current state of technology. The incentive for HIT use was once a bonus but converted into a penalty in recent years, but remained a measure in which one could either pass of fail, and failure resulted in a Medicare payment cut. CMS now proposes to give partial credit for components of HIT use, which should reduce the number who are penalized.

• Physicians Will Have a New Reporting Burden, But it May be Modest

While most of MIPS is composed of elements of existing programs, the legislation requires assessment of a new category called practice improvement activities. This portion of the MIPS program is an attempt to evaluate and give credit for structures that improve care. CMS proposes that a long list of activities (participating in an alternative payment model, being a patient-centered medical home). CMS divides activities into high and medium value and proposes to require reaching a score which will likely require reporting on a few activities. Some of these activities may be reported by vendors and others may be reported by the physician.

In the next eight weeks, ASH staff and leadership will examine the proposed to determine the risks and opportunities for hematologists and the patients that they treat. The Society will submit comments in advance of the June 27 deadline.

To view the MACRA Quality Payment Program Timeline, click here