Oct. 17, 2016 — On Friday, Oct. 14, the Centers for Medicare and Medicaid Services (CMS) announced the final reporting requirements for its new MACRA rule going into effect Jan. 2017. This new program is about to turn how you are paid completely upside down.  

Based on MACRA, your Medicare reimbursement will be increased or decreased depending on how well you perform on a revised set of quality and cost metrics. And to make it worse, you have just a few weeks to begin complying with these new requirements.

Currently, CMS’s 2,398-page Final Rule only provides you with information for 2017 (your first reporting year). The agency called 2017 a “Transition Year,” indicating that additional changes will follow for future reporting years.

MACRA includes two Quality Payment Programs (QPPS):

• Merit-based Incentive Payment System (MIPS) – Most providers will report under MIPS during the first year. MIPS is basically a consolidation and refinement of various CMS incentive programs previously in place (i.e., PQRS, Meaningful Use, etc.).

• Advanced Alternative Payment Models (APM) – If you are one of the 5% to 8% of providers who qualify to report under APMs (which isn’t easy), you’re excluded from reporting under MIPS. If you comply with APM requirements, you’ll receive a lump sum payment at the end of the year amounting to 5% of the previous year’s fee-for-service payments.

Here’s a quick glance at next year’s biggest reporting changes based on the recent Final Rule release:

1. Low-Volume Threshold Raised: You’re only required to bill under MIPS if you bill at least $30,000 in Medicare Part B services OR see more than 100 Medicare patients per year. Approximately two-thirds of Medicare Part B providers will be required to report based on these criteria.

2. Cost Reporting: Although previous versions of the rule had cost measures as a key portion of your total MIPS score, CMS has changed this in the Final Rule. Although you will still report your cost metrics, they will not count in your first year of reporting (2017), and its “weight” has been transferred over to the Quality category of your composite score.

3. Clinical Practjice ent Activities (CPIA) Requirements Lowered: You’ll need to report four activities out of the 93 that are available for at least 90 days to avoid being hit with a penalty. However, if you are recognized as a medical home, you won’t have to report any.

4. Expansion of Advanced APMs: Previously experts anticipated that just about all providers would report their QPP data under With the expansion of more organizations into Advanced APMs, and the changes in the eligibility criteria, however, CMS estimates that between 70,000 and 120,000 (5%-8%) providers that bill Medicare Part B will actually qualify to participate in an Advanced APM in 2017. This is an important change because reporting data via an Advanced APM offers an automatic 5% incentive payment on all Medicare payments.

5. Advanced Care Information (ACI) Reporting Minimum Cut: ACI takes over the Meaningful Use program and measures how you use your electronic health records (EHRs). The good news is that MACRA’s Final Rule reduced the reporting criteria from 11 items to just five. However, you will need to report them all for at least 90 days to get a 100% score in this category.

6. First Year Reporting Volume Modified: The recent Final Rule changed what you are actually required to report to comply during 2017, and the penalties/incentives that accompany each:

1. 1. Non-reporting: If you qualify to participate in MACRA and don’t report, you will be hit with a 4% negative adjustment on your Medicare reimbursements. Currently, qualified providers are in all specialties and practices sizes and include: Physicians, PAs, NPs, CNSs, and CRNAs.
   2. Submitting Sample Data: If you just put your toe in the MACRA water and only submit a small portion of what is required, you’ll actually avoid a penalty (but won’t quality for an increase). If you take it a little bit further and report a part of the year, you’ll receive a neutral or small increase to your payments.
   3. Exceptional Performance Adjustment: If you dive in head first and report your QPP data for the full year, you’ll be eligible for a “moderate” pay increase. And as an added bonus, if you get a final score of 70 or higher, you could also receive the exceptional performance adjustment funded by $500 million set aside by Congress.

How you report your 2017 MACRA metrics will make a significant difference in your future Medicare reimbursement. It’s vitally important that you figure this out NOW,

During your first year of reporting your quality and cost MACRA data, you have the opportunity to mitigate your risk of future Medicare reimbursement cuts, but you have to know how.