David Sayen

Risky Business. Are You Ready for MACRA?

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It turns out Uncle Sam has a plan. He tried mightily to bend that stiff cost curve. He threw everything he had at it — fixed prices, automatic reductions, sophisticated relative value schemes. He could not do it. Turns out the pen (or mouse) is mightier than the sword because almost all of the Medicare benefit spend flows with the ink (or electrons) that is released by the physician’s hand. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is a game changer like prospective payment system (PPS).

Humans are inherently risk-averse. Doctors are humans. This new Part B payment scheme is going to make them uncomfortable. The Medicare Merit-Based Incentive Payment System (MIPS) puts a percentage of Part B reimbursement at risk — a modest 43% initially, but it climbs quickly. The Centers for Medicare & Medicaid Services (CMS) estimates 88% of eligible practitioners will be feeling that in 2019. This year more than 200,000 doctors (roughly two in five) were penalized for failure to achieve meaningful use of electronic health records in performance year 2014. Many have decided to just accept the reductions like the person who collects parking tickets because it’s just too much trouble to park in a lot.

Changes in the law can have unintended consequences. Prospective payment led to premature discharges from hospitals. The introduction of the physician fee schedule and sustainable growth rate targets led to an increase in the volume and intensity of services (or claims maybe). What will the consequences of MACRA be? Will the money at risk motivate physicians to be more efficient? Or will it lead them to shun traditional Medicare patients?

Yesterday, during a U.S. Senate Committee on Finance hearing on MACRA,  CMS seemed to acknowledge the challenges of releasing the final rule for MACRA in November 2016, then measuring physicians immediately after that in January 2017 for 2019 payment basis. Clients and prospective clients should be aware that the potential delay recently discussed by the CMS Acting Administrator is not a delay of MACRA implementation.  He referred to possibly delaying the start of the ‘performance year’ that will be used to adjust payments in 2019.  The need to prepare for value based Part B payment is pressing, and those that prepare soonest can turn MACRA into an opportunity.

We have been talking to clients and friends around the industry. We are seeing a lot of interest in the alternatives to MIPS, that is the Alternative Payment Model (APM) approach. Those programs like Pioneer Accountable Care Organizations (ACOs) that take meaningful downside risk clearly have the potential for growth and profit, but they are not for the faint of heart. We believe for group practices and hospitals that bill for physician services, the middle road shows great promise. That alternative is to develop a Medicare Shared Savings Program (MSSP) ACO that avoids downside risk initially. This is a “Track One” ACO — it lets providers have less exposure to complex MIPS reporting and the opportunity to get ready for a potential launch into a higher risk approach later.

On July 7, 2016, CMS further solidified their commitment to MACRA (alternatively the Quality Payment Program (QPP) with the announcement of the proposed rule updating payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) starting January 1, 2017. CMS is proposing modifications to the MSSP to update the quality measures set to align with the proposed measures for the QPP, changes to take beneficiary preferences for ACO assignment into consideration, and changes that would improve beneficiary protections when ACOs are approved to use the skilled nursing facility (SNF) three-day waiver rule. The writing is on the wall — CMS will continue to move towards standardization of government-sponsored health plans via clinical and financial policy to ensure dollars spent meet the goals of improved beneficiary health, better population health management, and a trend of cost containment.

Every organization in the healthcare industry will be impacted by MACRA; some will be directly impacted, others impacted indirectly, and some will be affected by unintended downstream consequences of the legislation. Regardless of whether you are a health plan, a provider organization or a vendor that supports providers or health plans, we can help.

Our experts can review operations to identify risks and opportunities, increase integration within clinical and pharmacy programs, design well-coordinated activities across multiple healthcare programs, and ensure that your organization’s infrastructure and tools are prepared for MACRA’s impact on the industry. From in-depth analytics and tactical support to thought leadership and strategic planning, we can help. Contact our team today >>



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Navigating the path to value. Elena Martin, GHG’s Senior Director of Provider Innovations, outlines the MACRA quality payment program. Read now >>

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David Sayen

About David Sayen

David Sayen is Senior Vice President of Client Relations at Gorman Health Group (GHG). In this role, David guides GHG clients in developing strategies to respond to rapidly changing federal program opportunities. David recently joined GHG after a distinguished career at the Centers for Medicare & Medicaid Services (CMS), most recently as the Administrator of the San Francisco Regional Office. Read more

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