Public Payers News

MACRA Implementation Solutions Payers, Providers Should Follow

Payers will need to align with MACRA implementation requirements in order to reduce administrative burden among their provider network.

By Vera Gruessner

MACRA implementation will take place across the healthcare industry starting next year, as more and more providers begin participating in Advanced Alternative Payment Models (APMs) and and the Merit-Based Incentive Payment System (MIPS). Commercial payers will need to keep up with the value-based care push coming out of the Centers for Medicare & Medicaid Services (CMS) or else they may place too much reporting and administrative burdens on their provider networks.

Advanced Alternative Payment Models

For instance, if private payers stick to fee-for-service payment arrangements or vary distinctly in their pay-for-performance reimbursement strategies from regulations surrounding MACRA implementation, providers will be scrambling to keep up with a wide variety of quality reporting and billing requirements.

Last week, Dr. Farzad Mostashari, Founder of Aledade Inc. and former National Coordinator for Health IT, spoke to HealthPayerIntelligence.com about commercial payers and how they are behind CMS when it comes to alternative payment models. Mostashari explained that following the templates set up by CMS in terms of aligning with value-based care and MACRA implementation requirements is beneficial for both payers and providers.

“I see some positive trends just in the past two years, but private payers, by and large, are still behind CMS in terms of making it easy for organizations to apply for and qualify for these models,” Mostashari said. “Medicare has an application process that is complicated but predictable whereas with many private payers, the process itself is opaque and the outcome uncertain. I would strongly suggest that private payers institute more predictable processes and requirements as well as boilerplate contracts that are based off of CMS templates and a clear process for how organizations can apply for and get those risk, value-based contracts.”

The Heritage Foundation also outlined in an issue brief some of the challenges MACRA implementation brings the healthcare industry. MIPS leads to a significant burden due to extensive reporting requirements. MIPS regulations are specifically complicated for smaller medical practices to meet and these providers may see more severe cuts to their reimbursement. Providers may actually see as much as an 18 percent reduction in their Medicare reimbursement over the next ten years.

Additionally, CMS has estimated that no more than 90,000 clinicians would be exempt from MIPS and able to participate in Advanced Alternative Payment Models. John S. O’Shea, M.D., Senior Fellow at the Heritage Foundation’s Center for Health Policy Studies, wrote about how to improve MIPS for providers. O’Shea suggests significantly reducing the reporting burden in MIPS in order to show more meaningful quality performance metrics. Physicians may benefit from reporting only on key measures that improve patient care instead of a more “arbitrary number of measures,” O’Shea said.

One other major issue within MACRA implementation is the limited number of Advanced Alternative Payment Models that providers can participate in. The type of models allowed are eligible under Section 3021 of the Affordable Care Act, which limits it to Accountable Care Organizations in tracks 2 and 3 of the Medicare Shared Savings Program or the Next Generation ACO model.

Additionally, research shows that accountable care organizations have actually not shown major progress in reducing overall healthcare spending for the Medicare program. O’Shea wrote that Medicare faced a loss of around $216 million due to the Medicare Shared Savings Program and ACOs. A loss to taxpayers was also apparent over the last three years.

O’Shea recommends for CMS to expand alternative payment models to move beyond the healthcare delivery strategies stemming from the Affordable Care Act. Otherwise, the current incentives for participating in Advanced APMs will be meaningless for most providers. Therefore, expanding the number of available alternative payment models is key.

When releasing the final rule for MACRA implementation, CMS did attempt to provide solutions for smaller medical practices to successfully meet MACRA requirements, according to Health Affairs. Physicians who collected less than $30,000 under Medicare Part B or saw fewer than 100 Medicare patients were exempt from participating in MIPS in the final ruling.

Additionally, CMS assisted smaller medical facilities by creating a “virtual groups” platform in which up to ten providers can report as one group for MIPS requirements. These “virtual groups” will likely be implemented by 2018. Mostashari also praised the steps CMS took to make it easier for smaller medical practices to participate in MACRA legislation.

“What CMS recognized in the MACRA rulemaking was that unless steps are taken to make it more feasible for smaller practices to stay independent, that does not lead to a good outcome either for public or private payers. It would lead to more market consolidation and less competition in provider markets,” Mostashari explained. “Recognizing that in MACRA, CMS did some very sensible things including streamlining the reporting requirements, making it possible for providers to report through multiple means - not just claims-based but also registry-based and  EHR-based quality reporting as well as virtual groups and ACOs. This is not always at the practice level but rather at the group level.”

For more information about the MACRA ruling, view this Department of Health & Human Services (HHS) announcement.

 

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