Halloween! Can you believe it? All across the country this evening youngsters will don costumes in search of Treats, adults will shepherd their kids through neighborhoods, or stay behind to distribute said Treats, and somewhere…Tricks will be played. I have fond memories of 10/31 from my youth, and I must admit part of those memories included an odd attraction to what my younger self perceived as the “scary” part of the evening. Speaking of scary things, some of us are a bit frightened by MACRA. I mean, let’s face it, 2,398 pages is enough to scare away almost anyone. Diana and Dugan have gotten us off to a great start unpacking the Trick that is MACRA. Let’s spend some time today looking at one of the Treats: the “Easy Button” that good Mr. Slavitt promised us a few weeks ago.
Pick your pace
In a classic case of foreshadowing, Andy Slavitt suggested in a blog post that providers would be able to “pick your pace” with respect to MIPS. True to his word, the MACRA final rule does indeed bear this out. At a very high level, pick your pace provides you with an important choice next year. If you are NOT participating in an Advanced APM (like an ESCO) in 2017, you have 4 options for MIPS. I have taken a few liberties, adding a bit of color to each of the 4 categories:
- The “Garrison Keillor” option—Chose full exposure to MIPS for at least 90 days because everyone in your practice is “above average” and you intend to rock the MIPS world and will strive to collect 104% of Medicare in 2019. To you I say, best of luck.
- The “Boy Scout” option—Dip your toe in the water next year to better prepare for a full run at MIPS in 2018, and maybe even collect a few bucks for your effort in 2019. You will also report for 90 days and can delay that start until October 2, 2017…if you dare.
- The “Easy Button”—Report next to nothing in 2017 and avoid the 4% haircut in 2019.
- The “Ostrich Syndrome”—Ignore MIPS. Unfortunately, you should have read the Acumen blog because you missed the boat, did nothing in 2017, and get to enjoy 96% of Medicare in 2019.
The Easy Button
In the spirit of the Treats of the day, we are going to focus on what it takes to fulfill the Easy Button option. I am going to assume, that unless you plan to hang ‘em up and retire prior to 1/1/2019, no one reading this blog is going to pick door number 4 above. Especially after I finish telling you just how easy our friends at the Agency have made option 3. As Diana Strubler pointed out in her Herculean post a mere 72 hours following the publication of this beast, CMS has removed the Resource Use category from MIPS next year. That leads to a serious overweighting of Quality next year for those brave souls contemplating options 1 or 2 above. For those of you selecting the Easy Button, removing Resource Use simplifies the choices before you.
Although we are literally weeks away from the start of my favorite sport, the trifecta of college hoops will have to wait. No, this 3-pointer is a reflection of the remarkably light load ahead of you in option 3. You basically get to pick one of the 3 remaining MIPS categories in 2017: Quality, Clinical Practice Improvement Activity (CPIA), or that perennial favorite, Advancing Care Information. Choose one, submit what amounts to a minimal amount of data, and you are in the clear for 2019. CMS is basically saying, show us you are trying during the “transitional year”, and we will not penalize you in 2019.
So what’s a doc to choose? Far be it from me to provide advice, but today is one of those special days. Let’s face it, ACI (meaningful use incognito) is something despised by all nephrologists capable of fogging a mirror on Halloween. Many of us have filed hardship exceptions for the past several years, and the mere thought of gearing up for another run at Meaningful Use Advancing Care Information is enough to send shivers down our spines. In order to punch the Easy Button with ACI, you will need to fulfill the requirements for the 5 base measures in ACI:
- Security risk analysis
- Provide patient access (to their health information)
- Send summary of care
- Request/accept summary of care
Thankfully, we have 2 more palatable choices: Quality and CPIA. The Easy Button from my perch is CPIA. Pick from among the activities that made the final rule (Table H in the appendix of said final rule), attest to the fact that you (or your practice) adopted this CPIA for 90 days in 2017, and you are done. What could be easier than that? By the way, those of you who are participating in an ESCO next year, given the complexity of the MACRA world and the simplicity of the Easy Button I just described, why not submit your own CPIA as an insurance policy of sorts? Remember, there are some rare circumstances where Advanced APM participants will face MIPS—talk about frightening!
Having championed participation in CPIA, there is a case to be made for reporting a single quality measure as your Easy Button option. As Medicare providers, none of us have been directly exposed to programs that pay us based on the quality of care we deliver. MIPS is about to change that in a major way. Starting 61 days from now, unless you are a participant in an Advanced APM like an ESCO, your future fee schedule will be dependent on some measure of the quality of the care you provide. One might make the case that during this “dry run” as CMS is calling the transition year, you practice collecting and submitting quality data, with an eye towards getting very serious about it in 2018. Many of you running the MIPS gauntlet will be looking at QCDRs like the one sponsored by the RPA. Perhaps 2017 is the test drive you’ve been waiting for?
Time to eat those Treats!
As we’ve mentioned in this blog before, MACRA is a serious game changer, with respect to the way physicians will be paid by Medicare in the future. Commercial payors are rapidly moving in this direction as well. The Easy Button Mr. Slavitt alluded to is indeed there for the taking, and in my view it is truly a Treat. The Trick, of course, is taking the Treat while preparing for 2018. Keep looking for opportunities to participate in an Advanced APM, as CMS promises more will be available in the years ahead. In the meantime, it’s going to be tough to avoid the lure of the MIPS Easy Button…Trick or Treat!
Terry Ketchersid, MD, MBA, practiced nephrology for 15 years before spending the past seven years at Acumen focused on the Health IT needs of nephrologists. He currently holds the position of Chief Medical Officer for the Integrated Care Group at Fresenius Medical Care North America where he leverages his passion for Health IT to problem solve the coordination of care for the complex patient population served by the enterprise.
Top image from www.canstockphoto.com
How many summary of cares do we need to send? How many to accept? If we are doing the ESCO, don’t we have to achieve those ACI goals? If we are doing the ESCO, should we to the ACI goal since we need to do that anyway? How many patients have to accept access to their information? Great .post. Thanks. RG
Terry Ketchersid, MD, MBA, Chief Medical Officer - Integrated Care Group says
Great questions RG and questions we’ll answer in detail in future posts. To “scratch” for ACI from the MIPS perspective next year, you need to be in business for 90 days and you need to have at least 1 patient for each of the required objectives, or answer “yes” to yes/no objectives. The ESCO ACI requirement is another issue and one that requires more than a comment to clarify. Basically CMS defines the requirements for an APM to be considered an Advanced APM. One of those requirements is for participants to use CEHRT. In the MACRA final rule, HHS clarifies the CEHRT requirement (sort of) by stating at least half of the eligible clinicians participating in the APM must use CEHRT as defined for MIPS. So yes, technically speaking if you are in an ESCO, half of the providers will need to pursue ACI…the other half however will not. Clear as mud, no?
How do we report for MIPS? Will it be the same way we reported meaningful use? We have not reported M.U. for a while as we received the exclusion. Or, is there a new website with a new registration that we have to utilize? What do you like least about the ESCO program? What do you like most about the ESCO program? What will the outcome modifier be in 2018? 2019? That is, to my understanding the first year of the ESCO we get a “free pass” on the outcomes as long as we report them, right? Looking forward to the blog this Monday.
Terry Ketchersid, MD, MBA, Chief Medical Officer - Integrated Care Group says
Again, great questions RG. Many of the answers are forthcoming in future Acumen blog posts. Between now and the end of the year we will feature a heavy focus on MACRA. Stay tuned!