MACRA Final Rule Released

In mid-October, CMS released the final rule about implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). This new Medicare payment program will replace the Sustainable Growth Rate (SGR) that was repealed in 2015.  MACRA emphasizes improving quality of care for patients and moving away from a fee-for-service payment system.

Under MACRA, physicians, nurse practitioners, physician assistants and clinical nurse specialists can choose to interact with Medicare either via a program called Merit-based Incentive Payment System (MIPS) or via qualified Alternative Payment Models. MIPS consolidates the current Medicare quality reporting programs into one merit-based payment system. The components of MIPS focus on quality, resource use (cost), Advancing Care Information (electronic health record use) and clinical practice improvement activities. “Clinical practice improvement activities” is a new component in Medicare payments and includes activities such as care coordination and implementing patient safety checklists.  Of note for addiction physicians, registering for and/or using a prescription drug monitoring program (PDMP) are two activities that count toward practice improvement under MIPS, with more weight given to using the PDMPs and less given to just registering.

Alternative payment models (APMs) are another way to interact with Medicare. This model of payment is developed to pay for clinical tasks that may not be paid for in traditional payment methods but would likely lead to improved patient outcomes. Physicians can earn rewards for better patient outcomes or be at risk for below-expected patient outcomes. Different types of APMs currently exist, many of them focused on primary care providers, and more APMs are in development.

For many addiction physicians who are either solo practitioners or part of a small-group, MACRA may not have much effect on payment for several years. Practices that have less than $30,000 in Medicare revenue or 100 or fewer Medicare patients from September 2015 to August 2016 will not be subject to any payment penalties for not reporting certain practice improvement activities. Medicare will determine if a practice does not meet this minimum and notify the practice in December. For practices that cross this minimum threshold, doing one MIPS activity for one patient will be sufficient to avoid a payment penalty in the first year (2017).

Both the Center for Medicare and Medicaid Services and the American Medical Association (AMA) have produced resources to help individual physicians and practices determine which parts of MACRA they may qualify for. The AMA has a MACRA Assessment that will generate a report about which elements of MACRA a practice may be subject to in 2017 based on a few questions about the practice. You must log in or create an account to access the tool on the AMA website, but you do not have to be an AMA member. The AMA is sponsoring a webinar on Dec. 6 at 8pm EST to learn more about MACRA. Click here to register.

ASAM will continue to monitor changes to MACRA for 2018 and beyond and be sure to share with our membership.