The first reporting year for MACRA is well underway at this point, yet a number of rules introduced during the legislation’s rollout have yet to be finalized. CMS typically reserves the right to revise certain aspects of its published guidance as large-scale programs unfold and opportunities for improvement arise. According to healthcare intelligence firm Leavitt Partners, MACRA is no different.
The following is a list of MACRA rules that haven’t been finalized or may be targeted for revision.
1. Virtual group standards
Rural and small practice physicians can band together for reporting purposes. Pinning down the conventions for this rule, along with how virtual groups would be identified for tax and billing purposes, appears to be a priority for lawmakers.
2. Non-patient-facing clinician criteria
Clinicians who are eligible for MIPS but perform 100 or fewer annual procedures that are considered patient facing have their own unique reporting category. The idea is that certain specialists, such as radiologists, anesthesiologists, and pathologists, need a separate set of metrics than physicians who treat patients face-to-face. CMS was supposed to notify any such clinician as well as outline alternative benchmarks last December, but as of March this has not happened.
3. Cross-cutting measures in the quality performance category
CMS is revisiting the requirement for clinicians to report one measure that can apply across multiple clinical settings. This was a requirement under the Physician Quality Reporting System and stricken from the final ruling, but CMS is exploring changes.
4. Advancing Care Information standards and reporting
ACI is supposed to replace the Meaningful Use program as one of the four key categories that contributes to a physician or group’s score in MIPS. It will be weighted at 25% of the overall score for 2017, and will not change over time like the weights in some of the other categories.
5. Standards for commercial payer Advanced APMs
Starting in 2019, CMS plans to allow physicians to use contracts with non-Medicare payers, such as commercial insurers and Medicaid as part of their Advanced APM portfolio.
6. Nominal amount standard for Advanced APMs
In order to qualify as an advanced APM, payers are required to be an expanded medical home model or bear “more than nominal financial risk”.
As is normally the case with looming CMS requirements, organizations should refrain from knee-jerk reactions. The best thing to do is to wait for the final ruling before committing any significant time or resources into the revision of workflows. Valant will keep up to date with any important MACRA updates as they pertain to behavioral health.
