- The American Hospital Association (AHA) recently published updated versions of its MACRA Tracker and MACRA issue brief to include changes introduced by the Quality Payment Program (QPP) proposed rule released last month.
The newly-modified MACRA Tracker displays areas where changes to the QPP are expected, possible, or unlikely based on the QPP proposed rule for calendar year (CY) 2018.
The issue brief outlined specific rules within the proposal clinicians should be aware of moving into the second year of the program.
“CMS laid out the initial regulatory framework for the QPP in 2016 and will finalize additional regulations by the end of this year,” wrote AHA in its MACRA issue brief. “How CMS implements the changes contained in the MACRA will have a significant impact, not only on physicians and other clinicians, but also on the hospitals and health systems with whom they partner.”
AHA highlighted that MACRA abolished the Sustainable Growth Rate (SGR). Instead, the program provides physicians with a stable—sometimes flat—update to the Medicare physician fee schedule payment rates from 2015 to 2025.
AHA added detail regarding the specifics of the Merit-based Incentive Payment System (MIPS) and advanced Alternative Payment Models (APMs).
“Beginning in performance year 2019, clinicians will be able to earn incentives for combined participation in Medicare advanced APMs and ‘other payer advanced APMs’ with non-Medicare payers (i.e., Medicare Advantage, Medicaid and private payers),” noted the association.
With the introduction of the CY 2018 CMS proposed rule, AHA highlighted the following notable proposals for MIPS participants:
- CMS proposes a “facility-based measurement” option that would allow for hospital-based clinicians to use their hospital’s value-based purchasing program performance in the MIPS.
- The agency also proposes to allow clinicians and group practices of 10 or fewer clinicians to band together in “virtual groups” to participate jointly in the MIPS.
- CMS also would extend the use of modified stage 2 requirements for the ACI category in 2018.
While the association issued a statement last month commending CMS for the proposed rule, AHA urged that CMS consider the following changes to the QPP in its issue brief:
- An expanded definition of advanced APMs that recognizes the substantial investments that must be made to launch and operate APM arrangements;
- A socioeconomic adjustment in the calculation of performance as needed; and
- Greater alignment between the hospital meaningful use program and the ACI category of the MIPS, and simplified ACI requirements.
AHA stated it will continue working with hospitals, health systems, and physician groups to prepare for MACRA implementation with these recent and potential changes at the forefront.
The association also emphasized the scope of impact MACRA will have on providers.
“Hospitals that employ physicians will defray some cost from implementation of and ongoing compliance with the new physician performance reporting requirements, as well as be at risk for any payment adjustments,” stated AHA. “Moreover, hospitals may participate in advanced APMs to help the physicians with whom they partner qualify for the advanced APM incentives.”
The opportunity for physicians and hospitals to meet federal reporting requirements as groups will be useful in fostering collaboration between providers, AHA stated.
“Finally, as a larger percentage of physician payment becomes at risk, there will likely be a continued shift in hospital-physician relationships, as hospitals and physicians seek greater collaboration on performance measurement and payment models,” AHA concluded.