Do you have your MACRA Implementation Road-map Ready?
We well understand that the majority of healthcare professionals wanted to see the repeal of SGR. However, on the other hand, we welcomed the Medicare Access and CHIP Re-authorization Act of 2015 (MACRA) which lays out two paths for adjusting providers’ Medicare fee-for-service payments: which are the Merit-Based Incentive Payment System (MIPS) and alternative payment models (APMs).
Studies clearly reflect that a majority of physicians in 2017 will be part of the MIPS group, despite the fact that 56% of them admit to not fully understand the intricacies of the Act. In this way physicians and healthcare systems find themselves at a crossroads, where the way forward entails creating new-found and newly forged alignments to cope with the myriad complexities of MACRA. With 90% of all Medicare payments switching to the value-based system by 2018, the need to start the journey of adaptation is a matter of top priority for all healthcare systems.
The latest survey by the American Hospital Association states:
“Hospitals employed more than 249,000 physicians in 2014 and had individual or group contractual arrangements with at least 289,000 more.”
With these type of enrollment numbers, healthcare systems across the country will not only be directly tied to the performance of their physicians but are obligated to shoulder the cost of performance evaluation. In a recent study by the CMS, it is predicted that an average practice will spend $40,069 per physician – capturing and deciphering metrics and taking roughly eleven hours per each evaluation in an hourly/metric/physician rubric. The same survey – in 2014 – showed that fully two-thirds of physicians did not see the value of the current metric captured.
Further, The New England Journal of Medicine stated in a 2014 publication that: “the quality-measurement enterprise in U.S. health care is troubled. Physicians, hospitals, and health plans view measurement as burdensome, expensive, inaccurate, and indifferent to the complexity of care delivery. Patients and their caregivers believe that performance reporting misses what matters most to them and fails to deliver the information they need to make good decisions.” The long-story-short of the narrative is this: developing ever more meaningless measures and designing additional incentive payment arrangements based on these measures will not fix the problem.
On the positive side, we can see that the final rule of MACRA allows a certain amount of flexibility built in, allowing smaller and independently run practices to decide their own pace of adoption – of course this rule comes with its own caveats, being either a full-year participation with submission of qualified, consistent data OR submitting ninety days of data and allowing for a small percentage of variation. But in one form and fashion or another, the 2017 data will need to be captured for reimbursement in 2019.
On the other side, regarding APM, Section 101(e) of MACRA promotes the development of, and participation in, Alternative Payment Models (APMs) with payment incentives from 2019 through 2024. Specifically, this section of interest:
● Creates a payment incentive program that applies to providers who are qualifying APM participants in the years from 2019 through 2024.
● Requires the establishment of a process for stakeholders to propose Physician-Focused Payment Models (PF-APMs) to an independent Physician-Focused Payment Model Technical Advisory Committee (PTAC) that will review, comment on, and provide recommendations to the Secretary on the proposed PF-APMs.
● Requires the establishment of criteria for PF-APMs for use by the PTAC for making comments and recommendations to the Secretary.
While the above outline may seem daunting at first, having a proactive approach to your MACRA implementation will enable your enterprise to not only understand the impacts of the Act, but to educate your team and help develop a robust and sustainable plan. A comprehensive baseline assessment will enable you to create your individual roadmap to success, as well as adhering to the rigid timeline laid out by the government.
Now consider the following points:
● In understanding the quality metrics you want to capture – with said metrics shifting between various specialties and practices – you want to be able to carefully analyze your strengths and weakness (SWOT).
● Once you know the metrics you want to capture, you must then identify an efficient methodology to collate the data in a robust and consistent manner. Your current EHR (Electronic Health Record) provider may not be able to adopt or adapt the methodology best suited to your needs. Here is where a thorough baseline assessment (including IT) will be an essential proactive approach.
● Conducting a baseline assessment will help you identify your model’s strengths and weakness. Then – with the relevant data captured – you will be able to see exactly where your resources are being funneled. Good data will be able to tell demonstrate the areas that are resource-intensive, which will allow you reassess. For example: changing the workflow allocated for chronic care management and transitional care management.
● Now you can create a timeline and roadmap of your path to effective MACRA implementation, fully understanding the risks and potential failure points, and develop a plan within your roadmap to mitigate risks (such as knowing how holidays and vacation periods will affect the 90 day data collection).
At this point you will have a battle-tested baseline assessment, which will provide tremendous insight into the inner workings of your organization, as it will:
● Identify and pinpoint breakthrough opportunities for operational improvements that will reduce or eliminate potential risks.
● Provide more in-depth insight into key functional areas and a complete view of what steps will be necessary for achieving peak cost-saving and operational efficiencies.
● Offer greater insight into organizational structure, identify potential gaps and personnel liabilities.
● Discover potential risks in talent, technology, operational processes, products, assets, and wide array of other areas.
● Document high-level process flows, identify strengths and vulnerabilities, prioritize key process-improvement opportunities, and provide a recommended action plan.
● Provide opportunity to enhance value through EBIDTA, gross margin expansion, and working-capital reduction.
It’s important to note that the above points only reflect the bird’s-eye-view of what needs to be accomplished to prepare for MACRA, and if not implemented correctly could well force physicians to choose between an overly burdensome pay-for-performance program and wholly impractical alternative payment models that are likely to be both professionally and financially unrewarding.
While, if implemented correctly, MACRA could give physicians a wide range of choice in how they prefer to practice and how to meaningfully measure the value of their care.
Although the passage of MACRA was a significant legislative event, it is the implementation of MACRA (along with other health care payment and delivery reforms) that will profoundly shape the future health the care system in the U.S.
ABOUT RACCA SOLUTIONS
Our goal is for our clients to achieve their peak performance. RACCA Solutions Group provides a multi-disciplined pragmatic approach that adds value to your business. We partner with our clients throughout a process that focuses on us listening to your ideas and goals and then developing practical solutions that lead you to your targets. Working together, we develop solutions to achieve your goals. Our approach is simple and battle-tested.