Oct. 14, 2016 — There can be no more speculation as to whether the Centers for Medicare and Medicaid Services (CMS) will go live with its Medicare Access and CHIP Reauthorization Act (MACRA) regulations on Jan. 1.

Earlier today, CMS released the final MACRA rule after considering more than 4,000 comments and having 100,000 attendees to related MACRA sessions where participants called for flexibility, simplicity and support for smaller practices. Here is a snapshot of several of the key elements of the 2,400-page final MACRA rule.

2017 Transitional Period Defined

CMS stated that it will consider the 2017 performance period for the 2019 MIPS payment year to be a transitional period “as part of the development period in the program.” During this transitional year, the agency will lower the MIPS performance threshold to three points (rather than four). And if you achieve a final score of 70 or higher, you will be eligible for the “exceptional performance” adjustment, which is funded by a pool of $500 million set aside in the MACRA legislation.

To be considered as a full MIPS participant and achieve the highest final scores, CMS indicated that you should submit measures and activities associated with these three performance categories:

• Quality — Report six quality measures or one specialty-specific or subspecialty-specific measure set.
• ACI — Report on five required measures.
• CPIA — Engage in up to four activities (rather than six activities as outlined in the proposed rule)

Cost Category Reporting

The Cost performance category will be lowered to 0 percent for the 2017 performance period to allow the agency to address related public comments.

First Year (2017) Modified Reporting Options Clarified

CMS refined your options for first year reporting requirements associated with the MIPS program. You will choose from one of the following for 2017:

Option 1: You MUST report full MIPS data for a full 90-day period or, ideally, the full year. This maximizes your chances to qualify for a positive rate adjustment at the end of the reporting period. In addition, if you qualify as an “exceptional performer,” as shown by your submitted practice information, you are eligible for an additional positive adjustment for each of the program’s first six years.

Option 2: You MUST report MIPS data for a period of time less than the full year, but for a minimum of a full 90-day period. During this time, you are required to report more than one quality measure, more than one Clinical Practice Improvement Activity (CPIA), or more than the required measures in the Advancing Care Information (ACI) performance category. Do all this to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.

Option 3: You MUST report one measure in the Quality performance category; one CPIA; or report the required ACI measure and avoid a negative MIPS payment adjustment. Alternatively, if you don’t report even one measure or activity, you will receive the full negative 4 percent adjustment.

Option 4: You MUST participate in Advanced APMs, and if you receive a sufficient portion of Medicare payments or see a sufficient portion of Medicare patients through the Advanced APM, you will qualify for a 5 percent bonus incentive payment in 2019.