MACRA and the Future of Primary Care: Strategic Preparation for Success John D. Goodson, MD Associate professor of medicine Harvard Medical School Massachusetts General Hospital Boston How are doctors paid? Payment Policies Congress with Executive Approval Medicare (1965) Medicaid (1965) RBRVS (1989) HITECH (2009) Affordable Care Act (2010) MACRA (2015) Policy Implementation Executive branch: Center for Medicare and Medicaid Services (CMS) RBRVS Physician Fee Schedule, 1992 Sustainable Growth Formula, 1997 Meaningful Use, 2011 Health Care Exchanges, 2012 Value-based Purchasing, 2019 CMS makes the rules CMS issues the “Final Rule” January 1st, each year. These are the rules of payment. Baseball is a game of rules Basic terminology What we do: CPT (Current Procedural Terminology): What we do, descriptions of services. Proprietary to the AMA. Why we do it: ICD (International Classification of Diseases): The diagnostic code assigned to each disease or condition, ICD 10 We are paid in RVUs (Relative Value Units, the “coin of the realm”) for each CMS service with an RVU value RBRVS is at the core of the MPFS We are paid in RVUs (Relative Value Units, the “coin of the realm”) for each CMS service Resource-based relative value scale (RBRVS) Assigns worth = “RVUs” to each CPT code Conversion factor 2016 = $ 35.80 3 components: Total RVUs = W + P + M » » » Work “…Clinical work…” (52%) Practice Expense “overhead” (44%) Malpractice “liability insurance” (4%) How are services defined and valuated? AMA’s CPT Editorial Panel and CMS define services CMS assigns value = Medicare Physician Fee Schedule (MPFS) AMA’s Relative value Update Committee (RUC) Congressional mandates IPPE, AWVs, TCMs CCM Professional societies MACRA: Beginning or ending? What is MACRA? Medicare Access and CHIP Reauthorization Act, MACRA (April 16, 2015) MACRA • Ended the SGR • A poorly conceived health care cost containment strategy that plagued professional payments with an annual downgrade without additional funding. • 12 years, 2013-15, 17 patches, $169.5 Billion • Consolidated many overlapping and redundant reporting requirements from MU to PQRS. MACRA’s “value proposition” Health care costs will “bend” down • Payment incentives for “quality” will improve the value of health care expenditures • Payment incentives for doctors to accept more than “nominal risk” • Large organizations will agree to administer and doctors will be willing to be aggregated Where to small and independent practices fit into MACRA thinking? MACRA Payment Options Alternative Payment Models for those qualified (likely only enterprises) The Merit-based Incentive Payment System (MIPS) for everyone else. MACRA is built on the current Medicare Physician Fee Schedule(MPFS) with powerful incentives. APMs (Alternative Payment Models) Eligible APMs Base payment on quality measures comparable to those in MIPS Require use of certified EHR technology Risk defined: Bear more than “nominal” financial risk for monetary losses OR Be a medical home model expanded under CMMI authority Qualifying APM participants Physicians and other clinicians who have a certain % of patients or payments through an eligible APM MIPS changes how Medicare links performance to payment Physician Quality Reporting Program (PQRS) Value-based Payment Meaningful Use Merit-Based Incentive Payment System (MIPS) Source: www.lansummit.org/wp-content/uploads/2015/09/4G-00Total.pdf How will Physicians and Clinicians be Scored Under MIPS? Quality 0-30 Resource Use 0-30 Clinical Meaningful practice use of improvement certified EHR activities technology 0-15 0-25 MIPS Composite Performance Score 0-100 0-100 Points, < 25 points is penalty threshold Source: www.lansummit.org/wp-content/uploads/2015/09/4G-00Total.pdf MIPS Timeline 2016 November 1: MIPS reporting expectations 2017 July 1: Initial feedback from CMS on MIPS scores 2018 July 1: CMS establishes attribution models January 1, 2019: MIPS and APMs start MIPS Adjustments UP OR DOWN: 4% in 2019 >> 5% in 2019 >> 7 % in 2020 >> 9% in 2021 Bonus adjustment (not budget neutral, 2019 through 2025, $500 M allocated). APMs: 5% upward adjustment for 5 years MIPS penalties and APM incentives AMP 5 year 5 % incentive and MIPS 5 year reductions in Medicare payments for MDs with composite scores < 25 2017 2018 2019 2020 2021 2022 2023 + 5% APMs MIPS adjusted - 4% 30 months - 5% -7% - 9% How Much Can MIPS Adjust Payments Upward? MAXIMUM Adjustments 4% 5% -4% -5% 7% 9% Adjustments to provider’s base rate of Medicare Part B payment -7% In addition, those who score -9% 2019 2020 2021 2022 onward in top 25% are eligible for an additional annual performance adjustment of up to 10%, 2019-24 (NOT budget neutral). Source: www.lansummit.org/wp-content/uploads/2015/09/4G-00Total.pdf Details unclear Quality (0-30 points) Disease treatment CV: Hypertension (<140/90), Beta blocker for 6 mos. post acute MI Diabetes care: HbA1c <9%, foot care, eye, nephropathy Asthma: Persistent on controller medications Prevention Ischemic vascular disease on ASA Tobacco cessation screening and cessation Screening Cervical CA screening Breast CA screening, 50-74, biannual Colorectal CA screening BMI screening and follow up Patient experience (CAHPS) Meaningful Use (0-25 points) Clinical Functionality – 15 Criteria Care Coordination & Clinical Quality measures (CQM) – 13 Criteria Privacy and Security – 11 Criteria Design and Performance – 9 Criteria Patient electronic Access and Secure Messaging – 9 Criteria Public Health Reporting – 7 Criteria Resource Use (0-30 points) Your clinical Care No cervical CA screening, <21 yrs No imaging for LBP Avoidance of antibiotics in bronchitis But what about… Clinical care delivered by colleagues Clinical care driven by patient demands Practice Improvement (0-15 points) Access Same day appointments Care delivery Medication reconciliation Population management Communication Test results communication Plan of care (POC) for complex patients Shared decision-making “MOC assessments” APMs vs. MIPS FFS? Surviving and thriving • • • • • • High quality primary care Patient engagement Optimize charting Use the Primary Care codes Panel management Find your allies High quality Primary Care • A clinical interface to support key workflows • Clinical encounters • Communication, internal and external • Non face-to-face care management • Results management and disposition • Decision support resources • Clinical decision support • Crowd sourcing • Education and learning Patient Engagement • Portal • Previsit work • Intervisit communication • Devices • Communication • Open scheduling • After hours coverage Optimize Charting • Organize clinical thinking to support the complexity of your work • Chronic care management • Problem orientation • Risk adjustment Problem oriented charting • Problems become the indexing tool for clinical care • Documentation of medical decision making related to each problem • Linkages to outputs • Testing • Referrals • Billing • Prior approvals Use the Primary Care Codes • Evaluation and Management (E/M) • • • • Welcome to Medicare (IPPE) Annual Wellness Visits Transitional Care Management Chronic Care Management Service Codes: Know your RVUs 2000 2005 2010 2015 IPPE, 2005 (4.70) 2020 2025 2030 AWV codes, 2011 (4.85/3.26) TCM codes, 2013 (6.79/4.82) CCM code, 2015 (1.19) E/M codes (99214=3.13) Panel Management • Reporting • Find outliers • Clinical management tools for: Hypertension, Diabetes, Hypercholesterolemia, Depression • Coaching • Portals • Educational resources (“health literate”) Find Your Allies • Professional societies • AAFP • ACP • AOA • Congress • EHR vendors that anticipate the future • Agile • Responsive • Service oriented Can the MPFS be changed? NEJM OnLine March 9, 2016 Berenson and Goodson The call to action: “Implementing new incentives and quality measures in new payment models while maintaining broken fee schedule is a prescription for failure.” Write a letter “There is no way from me as an active primary care physician to achieve the goals of MACRA for improved value from Medicare payments unless there is a substantial and meaningful increase in the valuation of the core outpatient established patient service codes, 99213, 99214 and 99215.” Bottom line 1. 2. 3. 4. MACRA will ripple through MD payments for the years to come. Ignore at your own peril. MIPS is a FFS adjuster with opportunities for improved patient care and better compensation Dates to remember: July 2016: Composite metrics defined July 2017: MIPS scores reported July 2018: Attribution model established Begin planning Plan for success Thank you Questions?
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