Under MACRA, the merit-based incentive payment system (MIPS) automatically applies to eligible clinicians (generally a physician or mid-level – see our previous blog post for details) and most clinicians who treat Medicare patients are expected to be included in MIPS. As a result, one of the most common questions about MACRA is when it starts. CMS’s final MACRA rule confirms that implementation begins Jan. 1, 2017.
The 2017 year is being treated as a transitional year. During this year, clinicians may start reporting data used for MIPS determinations (including advanced alternative payment system (APM) qualification). In its final rule, during the 2017 transition year CMS creates five options for clinicians who are not excluded from MIPS:
|1. Do Nothing. Clinicians may abstain from reporting any MIPS data or participating in an advanced APM.||Full, negative 4 percent (-4%) payment adjustment in 2019.|
|2. Minimal Reporting. For any time period, clinicians can choose to report: one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category.||Avoids a negative MIPS payment adjustment.|
|3. Moderate Reporting. For at least a full 90-day period, clinicians can choose to report to MIPS: more than one quality measure; more than one improvement activity; or more than the required measures in the advancing care information performance category.||Avoids a negative MIPS payment adjustment and creates opportunity to possibly receive a positive MIPS payment adjustment.|
|4. Full Reporting. For the full 2017 year, report: six quality measures (or one specialty-specific or subspecialty-specific measure set); five advancing care information performance measures; and four improvement activities performance category measures.||Avoids a negative MIPS payment adjustment and maximizes opportunity to possibly receive a positive MIPS payment adjustment.|
|5. Participate in an Advanced APM. Clinicians may seek to receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through an Advanced APM.||Qualify for a 5 percent bonus incentive payment in 2019.|
Importantly, these transition year options only apply to 2017. In 2018, full-year reporting in all categories, including cost performance (which is weighted 0 percent in the 2017 transition year) will be necessary unless CMS expands the transitional period. CMS thinks the transition may take longer than one year and anticipates making proposals for 2018 during the 2017 transition year.
Given the options above, every clinician should try to achieve at least the minimal reporting requirement to avoid the negative payment adjustment in 2019. If possible, it is likely the best strategy to seek full reporting during 2017 so that clinicians are prepared for later years – the 2017 transition year will allow clinicians to try out various measures to see which are best and to obtain feedback from CMS. The experience and feedback obtained by clinicians reporting in 2017 are likely to help position these clinicians to achieve greater positive payment adjustments in later years.