CMS Expands Exemptions and Flexibility in Final MACRA Rule

Guest post Ken Perez, vice president of healthcare policy, Omnicell.

Ken Perez
Ken Perez

On October 14, the Centers for Medicare & Medicaid Services (CMS) released a 2,171-page final rule for the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS had issued a proposed rule on April 27 and in the intervening period, more than 100,000 physicians and other stakeholders attended outreach sessions and CMS received more than 4,000 public comments on the proposed rule, with many of the expressed concerns pertaining to the start date for MACRA’s first performance period.

MACRA’s Quality Payment Program replaces the unpopular sustainable growth rate formula and defines how physicians in physician practices—not hospitals—will be reimbursed by Medicare. It features two alternative, interrelated pathways: the Merit-based Incentive Payment System (MIPS) and advanced alternative payment models (APMs). MIPS is designed for providers in traditional fee-for-service Medicare, while the advanced APMs are for providers who are participating in specific value-based care models, such as accountable care organizations (ACOs).

Small physician practices with less than $30,000 in Medicare charges or that see fewer than 100 Medicare patients per year are exempt from MIPS. According to an analysis by the American Medical Association, 30 percent of physicians are below one or both of these thresholds. In addition, providers new to Medicare in 2017 are also exempt (though just for the first year).

The proposed rule specified Jan. 1, 2017, as the start date for the first performance period under MIPS, which would drive calendar year 2019 payment based on performance in 2017 across the four MIPS categories: Quality, Advancing Care Information, Clinical Practice Improvement Activities, and Cost/Resource Use. The final rule allows providers to start collecting performance data anytime between Jan. 1 and Oct. 2, 2017, with data due to CMS by Mar. 31, 2018.

Under MIPS, physicians can earn in 2019 a payment adjustment that is neutral, up to 4 percent positive, or up to 4 percent negative, depending on their level of participation, the amount of data submitted, and the length of the performance period reported. The adjustment increases to plus or minus 5 percent in 2020, plus or minus 7 percent in 2021, and plus or minus 9 percent in 2022. CMS projects that 592,000 to 642,000 clinicians will submit data for MIPS during the first performance year.

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Healthcare IT Regulatory Compliance Drives System Interoperability

Chris McNabb
Chris McNabb

Guest post by Chris McNabb, general manager, Dell Boomi.

Many healthcare IT organizations find themselves caught between a regulatory rock and a technological hard place. The breadth and increasing complexity of today’s healthcare regulatory compliance is putting tremendous pressure on them to rapidly and efficiently establish interoperability between the variety of systems, applications, data sources and devices that populate the diverse healthcare ecosystem of providers, payers, government agencies, labs and more. However, most of these IT departments don’t have adequate budgets, resources and bandwidth to make major investments in new technology while also maintaining expensive legacy systems and trying to manually consolidate their highly fragmented data silos. Instead, they remain mired in outdated application integration strategies based on traditional middleware solutions that require long and costly development cycles, making it impossible to satisfy the new and ever-changing regulations anytime soon.

There is a better way. Integration Platform as a Service (iPaaS) enables the rapid and economic integration of applications in cloud-to-cloud, cloud-to-on-premises, and on-premises-to-on-premises integration scenarios. Because iPaaS is offered as a service, similar to the way Software as a Service (SaaS) is delivered, the barrier to entry is dramatically lower and the shift from CAPEX to OPEX delivers predictable costs. And because the integration will work with existing applications, IT will be able to focus immediately on meeting the challenges of the most significant new regulations, such as meaningful use, accountable care and the ICD coding standard. Let’s examine these regulations for their application integration challenge and see how iPaaS can help.

Meaningful Use

Even as healthcare organizations work to digitize their medical and clinical records, the requirement for meaningful use of certified electronic health record technology (CEHRT) means that the use of patient records needs to directly benefit patients through greater portability across health and insurance systems. This in turn requires IT to establish new, complex processes for recording patient information as structured data and exchanging summary care records. Several system providers and consulting firms offer solutions designed to overcome the portability challenge, but their proprietary interfaces can be a significant downside. As a result, the healthcare industry has been slow to attain compliance with the “meaningful use” requirement for EHR technology.

Accountable Care

Accountable care organizations (ACOs), which are designed to dramatically improve patient services, come with a new payment model. Instead of direct payments for services rendered, ACOs get paid based on the overall health of a population within the boundary of a defined community. Actually receiving payment, however, requires the ACO to produce a new set of metrics that must be collected from multiple systems, including EHRs, the Physician Quality Reporting System (PQRS), a variety of legacy on-premises applications, and the many new cloud applications that health organizations are adopting. The data must then be rapidly integrated for analytics and measurement. If this integration can’t be done rapidly, securely, and at a relatively low cost, the ACO model simply won’t work.

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