Though created in 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) really sat down at the table and demanded our attention last year. That is because 2017 was the first year for data collection under this new CMS value-based payment program.
The American Academy of Neurology (AAN) made a big push to get this information out to their constituents last year. They even developed the Axon Registry to help collect the data. This means that many neurologists are now on board and ready to avoid CMS’s penalties, and maybe even get bonuses, for their practices in 2019. If you are not among them, there is still time.
Why does it take two years for bonuses and penalties to come into effect?
The first thing you may notice about MACRA is that it follows a two-year cycle; patient data collected in 2017 will affect your bottom line in 2019.
Why does it take so long?
This was a question we asked Eric M. Cheng, MD, MS, a neurologist on the AAN Practice Management & Technology Subcommittee. The answer has to do with processing time, which doesn’t even start until the collection year has ended. “The penalties from  come in 2019 because it takes three months into 2018 for [neurologists] to submit the data,” says Cheng. “It then takes CMS a few months to actually process it and figure out who gets a penalty or not.” By the time this is all completed, yet another year has gone by.
We are still in the first of the two-year cycles because CMS gives you that buffer to submit data. They know that when the year ends (in December) practitioners will need some time to get all their information together. The deadline to submit your 2017 data is March 31, 2018 with one caveat: CMS Web Interface users have until March 16, 2018.
How do you submit patient data under MACRA?
Clinicians need to submit their data via the CMS Quality Payment Program using one of two pathways:
- The Merit-based Incentive Payment System (MIPS)
- Advanced Alternative Payment Models (Advanced APMs)
If this is completely unfamiliar, read this: Together Let’s Dip Our Toes into the MIPS Pond
To collect and then submit patient data, Cheng says you need some sort of electronic system to capture quality. This will also help you monitor the data yourself so that you are not completely reliant upon the payer to tell you how you’re doing. “We know they can make mistakes. In the world we live in, all payers are going to want to monitor value. Maybe the specifics will change for each payer, but it’s going to be really hard to do so without an electronic means to capture that information.” Meaning, now is the time to get involved in quantifying your quality of service.
What is new for 2018?
At the end of 2017, CMS announced new eligibility criteria for their Merit-based Incentive Payment System (MIPS). Cheng says this will definitely exclude more of the small neurology practices. Here are the two most important changes:
Inclusion criteria for MIPS has changed
For 2018, you are eligible for MIPS if you are a physician, PA, NP, or Clinical Nurse Specialist or certified registered nurse anesthetist and
- You take care of more than 200 medicare patients a year (up from 100 last year).
- You bill more than $90,000 a year in Medicare Part B charges (up from $30,000 last year).
The cost component of MIPs takes effect
MIPS has a scoring system with four components. One of them is cost, which wasn’t talked about much in 2017, because it actually had 0 percent weight. “This year, it becomes 10 percent,” says Cheng. “Next year, it goes up to 30 percent. Something that could have been completely ignored in the past all of a sudden becomes a contributor to MIPS.”
Cheng himself talks in depth about the cost component in this webinar produced by the American Academy of Neurology.
A big question asked last year was whether MACRA would still be relevant in 2017, considering the outcome of the presidential election and the potential repeal of the Affordable Care Act. Well, the year has come and gone and MACRA is not only here, it is moving forward into the future. It is time to get on board.