Gastroenterology Coding Alert

Get answers to MACRA delay: the truth, the timing, and the options CMS is doling out.

The looming payment overhaul, in the form of Merit Based payment System as per the MACRA is due to be implemented next year. Subsequent to enormous feedback to push back the implementation date, CMS has been considering the possibilities of adjustments in the initial performance period. Whether there would actually be a delay in implementation is yet to be seen. The truth is that the agency has not announced any delay as yet. Keep reading (with fingers crossed) for a lowdown on how MACRA helps you, the related issues, and the solutions that CMS has foreseen for you.

The rule as it stands now: As per the Medicare Access and CHIP Reauthorization Act (MACRA) proposed rule, CMS has stated the initial performance period will be January 1, 2017, to December 31, 2017. Where providers will have to begin reporting quality data, as well as begin tracking various quality indicators CMS will announce individual physician composite performance scores in late 2018. The Medicare reimbursement incentives or penalties, starting 2019 would be based on this data. “The specific quality indicators applicable to a gastroenterology practice have not been determined,” says Michael Weinstein, MD, former representative of the AMA’s CPT^® Advisory Panel. “Providers will need to keep their eyes and ears open to learn about the options being considered.”

CMS Feels the Provider’s Pain Points

Despite the given picture that MACRA is here to encourage better quality standards, there are opinions that MACRA actually may not eventually be able to achieve much improvement in patient’s health at large, as expected. Rather some feel that, what may ensue could be increased costs of care, lesser provider efficiency and patient’s autonomy.

Small practices to suffer: It’s true that small practices may find it difficult to meet the new quality-reporting requirements of MACRA. Also, physicians who miss the bus of quality reporting thresholds under MACRA may have to face cuts of up to 9 percent of their total Medicare payments in future years.

Documentation prevails over real care: Physicians may have to steal time out of that devoted to patient care in order to report the requisite data. Even CMS seems to be considering not to foster too much of a change on an already burdened physician practice.

PHI vulnerability: This has been voiced as a major concern, as the demographic and health data of patients will be freely accessible to insurers, contractors, and many more.

Fate tied to numbers: Further, The MIPS composite score, based on arbitrary statistical calculations, is going to decide your payments, which be far removed from the ground reality and may have no bearing on the merit of the individual provider’s quality care.

Know What Options CMS Has for You

Although CMS officials “remain open to multiple approaches,” according to Andy Slavitt, Acting Administrator, CMS in a testimony to the Senate Finance Committee, it is worthwhile to note that not even once did he mention the word “delay.”

Check for yourself: Go to Andy Slavitt’s statement in U.S. Senate Finance Committee’s hearing on MACRA http://www.finance.senate.gov/imo/media/doc/CMS Testimony - MACRA (A. Slavitt) 7.13.16.pdf. and try searching for the word “delay.”

Senator Orrin Hatch (R-Utah), the committee chair pointed out that many providers wanted a six-month delay and said that CMS does have the flexibility to extend implementation. In response, Slavitt acknowledged CMS had received significant feedback on this point, and that the agency remained open to the option of an alternative start date and shorter performance period. This might have been perceived as CMS’s favorable slant towards possibilities of delay, and you know the rest of the story.

Here are some of the alternatives that have been suggested from various ends, so as to let this implementation go easy on providers:

• Postponing implementation
• Establishing shorter reporting periods
• Reporting requirements to be adjusted to ease the burden on physicians
• Procurement of data directly through an automated database such as a registry, so that physicians are spared the task of reporting in those categories
• Practices that are performing well in a particular area may be allowed to forego reporting in that area
• Reporting may be waived for physicians who do not see too many Medicare patients.

Way to go: CMS feels that MACRA implementation needs to begin on the right note, so that providers feels that they are in sync and set up for success. In fact, CMS is considering publishing an interim final rule this fall to allow the agency to receive additional feedback. A final rule on new payment models under MACRA is expected to be announced in November.

“Because most single specialty gastroenterology practices do not provide much primary care it may be difficult to comply with the requirements that are being discussed for MIPS,” Weinstein says. “Rather, GI groups will more likely need to find an acceptable APM where they are taking risk for the health outcomes and cost of providing care for disease conditions and/or procedure bundles.”

Make preparations: Although CMS’s stance suggests that there is a possibility of MACRA being delayed, providers will need to take it with a pinch of salt, and whether or not that will happen is still very much up in the air. It would be prudent on your part to start preparing, explore your options and getting to know the MIPS and APM payment systems well while there’s still time.