As expected, CMS has announced that they will give MACRA eligible providers several options through which they begin to participate in the MACRA legislated performance monitoring and payment system starting in January, 2017. These options range from simply testing the system by reporting data after January to partially participating in the system by submitting data for a part of the year to submitting data for the full year. The latter two of these three options allow providers to receive a modest payment bonus and all three of these options allow providers to avoid payment penalties in 2017.
Coker Group would further like to point out the following important points about MACRA:
- All eligible providers still need to carefully plan for how they are going to participate in MACRA by January of 2017. The program is obviously not going to be put off and will begin in some form for everyone within the next 3 months.
- Providers still need to think carefully about participating in an alternative payment model, such as the Medicare Shared Savings Program. This will exempt them from having to comply with the more onerous requirements of MIPS, to include one of the new options outlined above.
- In addition to considering which option providers will take regarding MACRA, all providers need to think about how they are going to accurately measure, collect and report their quality, cost efficiency and meaningful use of electronic health record data by January, 2017.
- All providers need to determine how they will improve their performance in the above areas and what clinical practice improvement activities they will utilize to do so.