Although the first reporting year for the Medicare Access and CHIP Reauthorization Act is already underway, changes are expected in subsequent years of the program as CMS continues to refine regulations, according to a recent whitepaper published by Leavitt Partners, a Salt Lake City-based healthcare intelligence firm.
Here are nine MACRA regulations that CMS has not yet finalized or is considering adjustments for, according to Leavitt Partners.
1. Virtual group standards. MACRA's virtual groups will allow rural and small practice physicians to band together for reporting purposes. Making this option available as soon as possible is a priority for HHS Secretary Tom Price, MD, according to the whitepaper.
2. Group identifiers. CMS is reviewing comments on how virtual groups would be identified for tax and billing purposes.
3. Low-volume threshold standards. This threshold — which would allow physicians who fall below the requirements of at least $30,000 in annual Medicare Part B charges or 100 Medicare patients to be exempt from participation in the Quality Payment Program in 2017 — aims to protect physicians in small practices. As of mid-March, the agency had yet to notify clinicians of their potential exemption from the program, according to a letter from the Medical Group Management Association.
4. Non-patient-facing clinician criteria. Non-patient-facing physicians under MACRA are those who are eligible for MIPS, but perform 100 or fewer annual procedures that are considered patient-facing. This category was created for radiologists, anesthesiologists and pathologists who may need different metrics than physicians who treat patients face-to-face. CMS was supposed to notify clinicians of their status as non-patient-facing before the start of the reporting period — which would have been in December — but as of mid-March had yet to notify clinicians, according to the MGMA letter.
5. MIPS alternative benchmarks. Physicians need to know if they qualify as non-patient-facing under MIPS because this status comes with different metrics because their practice is significantly different than patient-facing clinicians' practices.
6. Cross-cutting measures in the quality performance category. In the proposed MACRA rule, CMS planned to require clinicians to report one "cross-cutting measure," which are considered applicable across multiple clinical settings and were required under the former Physician Quality Reporting System that MACRA replaced. The requirement was stricken from the final rule, but Leavitt Partners flagged it as an area where CMS is exploring changes.
7. Advancing Care Information standards and reporting. The ACI category is one of the four key categories that contributes to a physician or group's score in the MIPS track, and it was intended to replace the Meaningful Use program. It is set to be weighted as 25 percent of the overall score for the 2017 performance year and not change over time, unlike the weights of some of the other categories.
8. Standards for commercial payer Advanced APMs. Beginning in the 2019 performance year, CMS will allow physicians to begin to use contracts with non-Medicare payers, such as commercial insurers, Medicare Advantage and Medicaid, as part of their Advanced APM portfolio.
9. Nominal amount standard for Advanced APMs. To qualify as an advanced APM, entities are required to be an expanded medical home model or to bear "more than nominal financial risk."
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