MACRA 101: Back to Basics Stephanie Glover Health Policy Analyst Erin Mackay Associate Director Health Information Technology Programs About us The National Partnership for Women & Families is a nonprofit, nonpartisan advocacy group dedicated to promoting fairness in the workplace, access to quality health care, and policies that help women and men meet the dual demands of work and family. Key health initiatives: Coalition for Better Care: A broad-based coalition of consumer organizations with a direct stake in improving health care quality for patients and family caregivers. Consumer Partnership for eHealth: Advancing health information technology in ways that benefit patients and families. 2 Agenda Context of MACRA Summary of MACRA provisions related to Medicare physician reimbursement Deeper dives into MIPS and APMs Intersection of MACRA and Meaningful Use Impact points for consumers Next steps and comment letters 3 MACRA: Shifting from volume to value Previous physician payment system, the Sustainable Growth Rate (SGR), implemented in 1997 Growing consensus of need to shift away from fee-for-service MACRA: Eliminates annual uncertainty (payment cliff) by repealing the SGR and stabilizing payment updates for physicians Extends key programs including CHIP, community health centers, and the performance measurement enterprise 4 Where are we now? Medicare Access and CHIP Reauthorization Act (MACRA) passed April 2015 Request for Information released September 2015 NPWF submitted comments November 2015 Notice of Proposed Rulemaking (NPRM) imminent.. Sent to OMB March 28 60 day comment period expected Final rules expected by November 2016 Consumer input will be critical! 5 Why should consumers care? Big takeaway: Meaningful progress toward paying physicians for value, not volume Establishes a merit-based incentive payment system (MIPS) Combines three physician-level incentive programs into one: Physician Quality Reporting System Value-Based Modifier Meaningful Use Electronic Health Record (EHR) Incentive Program Incentivizes the development of, and participation, in alternative payment models (APMs) 6 Worlds colliding: MACRA & Meaningful Use 1) Merit-Based Incentive Payment System (MIPS) Awards EP single composite performance score based on four categories: Meaningful use of certified EHR technology (one of four categories) 2) Alternative Payment Models (APMs) Use certified EHR technology (among other requirements) Technology certified by the federal government to include functionality necessary for fulfilling Meaningful Use requirements 7 What does MACRA do? Immediately replaces old SGR cycle with shortterm stable updates, then offers two paths Jan-June 2015 0.0% July-Dec 2015 0.5% 2016-2019 0.5% 2020-2025 0.0% 2026+ 0.25% MIPS 0.75% APMs Status quo: PQRS, Physician Value Modifier, MU Bonuses/Penalties through 2018 MIPS Bonuses/Penalties APM Bonuses 2019-2024 8 Unpacking the Merit Based Incentive Payment System (MIPS) Awards providers a single composite performance score based on four categories: 1. Quality Incorporates measures from the Physician Quality Reporting System 2. Resource use Incorporates the existing Value-Based Modifier 3. Meaningful use of certified Electronic Health Record (EHR) technology Incorporates measures from the EHR (“Meaningful Use”) Incentive Program 4. Clinical practice improvement activities NEW category! Includes activities regarding expanded practice access, population management, care coordination, beneficiary engagement, patient safety, etc. A physician participating in a practice certified as a patient-centered medical home will receive the highest potential score for clinical practice improvement activities. 9 MIPS scoring Four components contribute to a MIPS score from 1- 100: Changes in weighting: Quality is weighted at 50% in 2019, and 45% in 2020 Resource Use is 10% in 2019, and 15% in 2020 Meaningful Use can be reduced (but not below 15%) if >75% of providers are Meaningful Users 10 MIPS: Rewards and penalties Providers earn a 1-100 score based on performance from four MIPS categories Payment updates based on this score would be adjusted (up or down) by as much as: 4 percent in 2019 5 percent in 2020 7 percent in 2021 9 percent in 2022 Additional payment above performance threshold; capped at $500 million/year (2019-2023) 11 MIPS: Measure criteria Measures from existing programs; new and updated measures must be evidence-based and come through traditional rulemaking processes If new measures are not endorsed by a consensus-based entity (now NQF), CMS must first submit to a peer review journal Multi-stakeholder input is required, but emphasizes medical specialty societies over existing process 12 Incentives to participate in APMs Jan-June 2015 0.0% July-Dec 2015 0.5% 2016-2019 0.5% 2020-2025 0% 2026+ 0.25% MIPS 0.75% APMs Status quo: PQRS, Physician Value Modifier, MU Bonuses/Penalties through 2018 MIPS Bonuses/Penalties APM Bonuses 2019-2024 (5%) Special emphasis on testing APMs with specialists & small practices 13 Unpacking the Alternative Payment Models (APMs) Qualifying Model of Alternative Payment Models include: Models implemented through the Center for Medicare & Medicaid Innovation (CMMI) Medicare shared savings program Health care quality demonstration program Demonstration project required by federal law Three criteria: 1. Quality Measures Comparable to MIPS 2. Use of Certified Electronic Health Record (EHR) Technology 3. Bear “More than Nominal” Financial Risk Note: certain CMMI approved patient-centered medical homes would be exempt from financial risk 14 Impact points for consumers Setting priorities for: Patient Centered Medical Homes Alternative Payment Models The “meaningful use” of health IT The MIPS quality measure set Clinical practice improvement activities 15 Patient Centered Medical Homes Question: How will CMS define patient-centered medical homes? What we think: A truly patient-centered medical home is grounded in comprehensive and well-coordinated primary care. Exemplar patient-centered medical homes utilize care teams that partner with the patient and family caregivers, provide ready access to care, address patients’ unique needs and preferences, view patients and family caregivers as partners in care planning and treatment decision-making, and provide safe, timely, and effective care. Key issue to look for in the proposed regulation Alternative Payment Models Question: How will CMS define Alternative Payment Models? What we think: If designed and implemented correctly, alternative payment models have the potential to provide the comprehensive, coordinated, patient- and family-centered care patients want and need while helping to drive down costs. Only through meaningful partnership with consumers and family caregivers will we arrive at a transformed health care system that delivers on all three tenets of the Triple Aim – better care, better experience, and lower cost. Key issue to look for in the proposed regulation Meaningful use of health IT Question: How will Meaningful Use be integrated into new models of care under MACRA? What we think: Health IT is foundational to patient- and familycentered care. At a minimum, include Meaningful Use measures that address patient and family engagement and care coordination in both MIPS and APMs: Patient ability to view online, download and share health information Access and use requirements! Secure email messaging between providers & patients Incorporate patient-generated health data into EHRs Exchange, reconcile, and integrate data between providers 18 Meaningful use of health IT What we think: MIPS should retain following structural elements of Meaningful Use program: 100% attestation (providers must meet all required measures to succeed) Full-year reporting periods (vs. 90 days) APMs should encourage use of functionalities of Certified EHR technology not yet included in the Meaningful Use program, such as: Person-centered health and care plans Non-English language access (to educational materials and clinical information) Links to community resources, supports, and services 19 Measures that matter What measures are needed to evaluate MIPS and APMs? Measures that are important to patients: PROMs, care coordination, patient experience, patient-centeredness Outcome measures Patient experience measures: need information more quickly and shorter surveys Patient-reported measures, including functional health status and quality of life Cross-cutting measures, e.g., patient engagement, care coordination Measures to identify and address disparities Measures of appropriate use Measures for efficient use / total cost of care Composite quality measures: highly prevalent conditions, preventive care, surgery Other? 20 Next steps Coming soon: Notice of Proposed Rulemaking (NPRM) Additional webinars to analyze rule, gather reactions and feedback Plans for comment: National Partnership for Women & Families Coalition for Better Care Consumer Partnership for eHealth 21 Save the date! Clinical Practice Improvement Activities: What Consumers Want Thursday, April 28 3:00 pm Eastern http://npwf.adobeconnect.com/cpias/ Beneficiary / patient engagement Shared care planning Decision aids / medical discussion guides Other ideas? 22 For more information Contact us: Stephanie Glover Health Policy Analyst [email protected] Erin Mackay Associate Director, Health IT Programs [email protected] Follow us: www.facebook.com/nationalpartnership www.twitter.com/npwf www.twitter.com/CPeHealth Find us: www.NationalPartnership.org www.CampaignforBetterCare.org | www.NationalPartnership.org/CPeH 23
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