With several months of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) implementation under their belts, many providers are still working to get a handle on requirements and determine an appropriate strategy.
A recent Black Book Research report highlighted 10 top MACRA trends challenging providers, which included the need to optimize electronic health records (EHRs) and implement technology to support MACRA efforts. The survey of almost 9,000 physicians also included the following noteworthy findings:
- To eliminate administrative burdens and capital costs, 75 percent of physicians are considering selling their practices to hospitals or group practices.
- Among practices with three or more clinicians, 77 percent are seeking to buy a compliance technology solution for the merit-based incentive payment system (MIPS) by the fourth quarter of this year.
- According to 89 percent of the potential buyers, the primary reason for investing in MIPS support software is to decipher their earning potential under MACRA rather than to measure their quality improvement activities.
- Among users of the eight largest EHR systems, 83 percent are upgrading or optimizing their systems for MIPS compliance. whereas 72 percent of practices using other EHRs said they weren’t working with their vendor to ensure MIPS readiness.
- There is considerable interest in assessing MACRA readiness, with 80 percent of survey respondents saying it’s essential to perform a inventory of technology to see how far their existing EHR and other technologies can take them.
It’s clear that providers are experiencing a good deal of fear, uncertainty, and doubt as they seek to protect themselves from the financial penalties that are set to kick in for clinicians who fail to meet and/or report on MACRA’s quality improvement objectives.
Eligible clinicians who fall below the MIPS performance threshold have a lot at risk. In 2019, the first payment year, almost $200 million in payments will be redistributed from providers performing below the performance threshold to providers performing above the threshold. As MACRA ramps up, underperforming Medicare physicians could lose up to 9 percent of their payments, while the high performers could earn positive payment adjustment of up to 9 percent.
Unfortunately, many practices still don’t have the right systems and processes in place. Some providers continue to hold out hope that MACRA will be delayed or even canceled, but that’s unlikely under the leadership of HHS Secretary Tom Price, who was a strong proponent of the original MACRA legislation. In fact, it is likely there will be more payment models based on value in the future: As much as 80 percent of all payment programs are expected to be value-based by 2020.
Moving forward, providers should be mindful of the following of three considerations.
First, for 2017 reporting, CMS has identified 273 possible quality measures. Eligible providers must report on six individual quality measures, including one outcome measure, for at least 50 percent of their Medicare Part B patients. More quality measures may come in future years.
Second, to facilitate the measurement and tracking of quality improvement activities, providers need to be notified when patients have gaps in care. The best time to receive such alerts is at the point of care when the physician is documenting the encounter. For example, for the quality measure “tobacco use screening and cessation intervention,” a provider should be advised if the patient he or she is seeing has not been screened for tobacco use within the past 24 months. The physician can then perform the appropriate clinical activities and update the patient’s record as part of the standard charting workflow.
Third, MACRA requires physicians to document and report on the specific actions taken to improve the quality of care. For example, in addition to screening a patient for tobacco use, a physician must perform and document intervention activities for patients who have been identified as smokers. To facilitate the reporting process, quality improvement activities should be stored in a structured format and not as free text.
Financial success under MACRA requires providers to perform, document, and report on quality improvement activities. When care gaps exist, providers should be advised at the point of care; an alert after the fact is of minimal benefit. Physicians must find ways to meet compliance objectives without interrupting the documentation workflow.
MACRA brings with it some daunting changes for physicians. But with improved processes and supportive tools, physicians can succeed financially while delivering high-quality outcomes.
David Lareau is the CEO of Medicomp Systems, Chantilly, Va.