Pulmonology Coding Alert

CMS may publish interim final rule for additional feedback.

Your reporting as per the Medicare Access and CHIP Reauthorization Act (MACRA) might just get postponed until July 2017. Due to enormous feedback to push back the implementation date, CMS is now considering the possibilities of a delay in starting the data collection. Keep reading for a lowdown on how MACRA related issues and the solutions that CMS has foreseen for you.

Background: The Medicare Access and CHIP Reauthorization Act (MACRA) enacted April 2015 will change the way physicians get paid by Medicare. As per the proposed rule, most physicians will have to begin reporting quality data, as well as begin tracking various quality indicators to CMS beginning January 1, 2017. The Medicare reimbursement incentives or penalties, starting 2019, would be based on this data. "Physicians and staff should start learning how MACRA will affect their practices, and be prepared for it to begin at some point in 2017," says Jeff Berman, MD, FCCP, executive director of the Florida Pulmonary Society.

For those who think MACRA is unnecessary, this act has helped repeal the flawed SGR sustainable growth rate formula that could have led to a 21 percent cut to Medicare reimbursement rates. What's more, it also extends the Children's Health Insurance Program (CHIP) for two years and sets up a new, two-track Medicare physician payment system that emphasizes value-based payment models. Furthermore, "practices are concerned about selecting the right program," says Carol Pohlig, BSN, RN, CPC, ACS, senior coding and education specialist at the Hospital of the University of Pennsylvania.

CMS Sees the Provider Issues

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

Small practices to suffer: The next significant issue is that small practices may find it difficult to meet the MACRA's new quality-reporting requirements. 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. "Small practices are having trouble because they can't produce enough income to meet all the requirements being put on them," said Phil Roe, MD (R-Tennessee) in an interview with Medical Economics, http://medicaleconomics.modernmedicine.com.

Documentation prevails over real care: And then, there is this eternal dilemma: physicians will 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 Merit-Based Incentive Payment System (MIPS) composite score, based on arbitrary statistical calculations, will decide your payments, which may be far removed from the ground reality and also may have no bearing on the merit of the individual provider's quality care.

Know What Options CMS Is Brooding Over

According to the feedback CMS received from the providers, a huge majority seems to be in favor of delaying the MACRA implementation date. The other areas where CMS has collected detailed feedback include the definition of advanced alternative payment models (APMs).

To solve this situation, CMS officials "remain open to multiple approaches," said Andy Slavitt, Acting Administrator of CMS in a testimony to the Senate Finance Committee. "So, some of the things that are on the table, we're considering, include alternative start dates, looking at whether shorter periods could be used, and finding other ways for physicians to get experience with the program before the impact of it really hits them."

Here are some of the alternatives that have been suggested to ease provider implementation:

• 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.
• Finding ways to pay providers involved in chronic care at higher rates.
• Encourage the use of APMs, including bundled payments, medical homes, and prevention and team-based APMs.

"At this time, it would be easier to postpone implementation," says Pohlig. "Some of the other options require that the reporting requirements have been defined (in order to know if the other options are more feasible)."

The MACRA effect shows already: The Medicare's Oncology Care Model (OCM), initiated recently, happens to qualify as an APM model. Coincidentally, about 200 physician group practice adopted this, almost double the number expected to join in. Industry hawks believe the high incentives linked with APM's as the likely reason for this enthusiasm. However, you need not follow this speculative trend. "Because the requirements for the APM option has not be defined, practices do not know if they will qualify and therefore must, at minimum, prepare for MIPS," advises Pohlig.

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. With a final rule on new payment models under MACRA is expected to follow in November.

Although CMS's stance suggests that there is a possibility of MACRA being delayed, but 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, and getting to know the MIPS and APM payment systems well while there's still time.

"MACRA will be in effect soon, begin making the necessary preparation and transition so your practice does not experience payment delays and other pertinent issues," cautions Berman.

Use this time well: "Even if there is a delay, that should not mean that you should delay the preparations," says Pohlig. "The delay would give the practices more time to evaluate their systems and attempt to transition in an effective yet seamless manner."