MACRA is here – Are you ready?
Eric Wetherell, Healthcare Consulting Principal
The deadline for accumulating the minimum data to ensure that your organization does not receive a negative adjustment to your Medicare Part B reimbursement under MACRA in 2019 is December 31, 2017. Starting in 2018, you will need to collect data for certain categories for the entire year to mitigate the risk of a negative payment adjustment in 2020. Are you prepared?
What is MACRA?
The Medicare Access and CHIP Reauthorization Act of 2015, or MACRA, is a bipartisan legislative act that was enacted on April 16, 2015. This law initiated drastic changes in the way physicians, and certain other providers are, and will be, paid. As part of a larger push to value-based payment methodologies, MACRA established two payment tracks, the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). If you qualify under MACRA for one of these two payment tracks, your Medicare Part B payments will be influenced in future payment years depending on data that you submit, or do not submit, in a quality reporting year to the Centers for Medicare & Medicaid Services (CMS).
Adjustments to Medicare Part B payments, both negative and positive, will begin in calendar year (CY) 2019 based on CY 2017 data. The percentage of payments subject to performance evaluation will gradually increase as the program continues, resulting in greater risk being shifted to the provider. Whether an eligible clinician (EC) realizes increased or decreased reimbursement will depend largely on how they have prepared themselves in the move from volume to value based payments.
What should you do?
There are several steps providers should take in evaluating the impact that MACRA will have on their organization. Determining whether you qualify for one of the two payment models under MACRA is the first step in being prepared. If you do qualify, the next step will be to evaluate which payment model your organization would fall under, MIPS or Advanced APM, and then to determine what reporting requirements are applicable to you.
Each clinician or organization will have different requirements depending on several factors, and understanding which ones apply to you will help to ensure that the necessary data is being accurately tracked and reported. After gaining an understanding of the reporting requirements, as well as your current reporting structure, you can then begin to measure compliance as well as financial impacts.
Evaluating and implementing MACRA effectively requires planning and collaboration. As risk continues to shift to the provider under MACRA, as well as other value-based initiatives, it will become increasingly important for providers to develop processes to monitor and improve performance.
Taking the first step
Preparing for MACRA can be a complicated process as there are many variables to consider. Here are a few things to keep in mind.
1. Do You Qualify Under MIPS?
Before you get started, you must assess whether your organization meets the qualifications under MIPS. Each performance period will impact Medicare Part B payments two years later. If you haven’t already done so, it is important to begin your preparation efforts for MACRA as soon as possible to avoid negative payment adjustments, and to potentially achieve positive adjustments to your Medicare Part B revenue in future payment years.
2. Should you do a MIPS Readiness Assessment and Initial Impact Assessment?
A MIPS readiness assessment will help align your organization’s current reporting processes and measures to those included in MIPS, as well as identify your strengths and weaknesses relative to MIPS. This process will allow you to focus efforts around the requirements to maximize your reimbursement.
An initial impact assessment will help determine the potential impact of MIPS to your Medicare Part B revenue as well as the efforts necessary to drive maximum Medicare Part B reimbursement for your organization.
3. You’ve implemented MACRA. What’s next?
Post-implementation, you will want to continuously monitor your MIPS performance category tracking and reporting efforts.
Our healthcare team has extensive experience in the areas of Medicare reimbursement, regulatory compliance, revenue cycle, and financial impact analyses. Click here to learn more, or reach out to Eric Wetherell or Robert Gilbert.
Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.