MACRA Year Two Presents Opportunities for Organizations Creating an Actionable "Ask" of Policymakers -- A Connect 4 Specialty
On July 20, 2017, CMS released its Proposed Rule for how it envisions implementing MACRA Year Two. The policies proposed in this rule refine a process that began, albeit slowly, last year and will eventually transform how clinicians (beyond just physicians) will get paid for their medical-benefit professional services within a system of winners and losers. After reviewing comments (due in August 2017), CMS will issue a Final Rule that will be implemented January 1, 2018.
Clinicians continue to have a choice of two paths to get their annual “adjustments” (raises, bonuses, penalties). CMS continues to roll out this program, officially called the Quality Payment Program (QPP), slowly and iteratively, both from the clinician side as well as the CMS side. Low-volume (Medicare) clinicians do not have to participate, and this year, CMS proposed to raise the low-volume threshold, exempting more clinicians from this program for now.
There is an enormous amount of detail, with exceptions and alternatives at every turn, in this 1000+ page proposal. We have collapsed much of the detail into endnotes, to ensure the basic themes and structure are clear.
All eligible clinicians will have to take some action in 2018 to avoid a negative payment adjustment penalty (or receive a positive payment adjustment) in 2020. While the two-year lag between performance and payment impact may reduce clinician perceptions of urgency, the at-risk numbers – i.e., 4-5% of Medicare Part B billings – are significant. CMS' preamble discussion implying that adjustments could apply not only to professional services, but to Part B drugs included on MIPS clinician claims raises the stakes further.
We are excited to note CMS responded with action on many of our clients’ comments last year, including recognizing the unique needs of complex patients and adopting measure language that underscores the importance of patient goals and priorities in care planning. Listening carefully to a client’s concerns, turning it into a policy-based solution, creating an “ask” that policymakers can actually achieve, and showing them why and how to do it is our specialty at Connect 4 Strategies!
Patient groups should read carefully, and comment on the details of how and what clinicians are incented to provide in terms of practice improvements, adherence to quality measures, and health IT that better connects them to their care. Life science companies will likely want to review and comment with an eye towards appropriate quality measures, registries, etc., and the new call for measures CMS proposes.
Treatment decisions will surely be impacted by this program, so timely proactive engagement and clear, concise reporting protocols will separate the winners and losers among all stakeholder interests.
Connect 4 Strategies has developed a general summary of the rule, reducing over 1000 pages down to 8, and is working with stakeholders on particular details and specific provisions that offer them greatest opportunities and/or risk as they prepare to weigh-in in response to CMS’ call for comments. We have reviewed the various tables in the proposed rule to ensure our clients are aware of specific quality measures, improvement activities, etc. that are of direct interest to their portfolios and patients.