Policy Advisory
Policy Advisory Medicare Access and CHIP Reauthorization Act of 2015 (Public Law No: 114-10) On April 16, 2015, the law to repeal and replace Medicare’s Sustainable Growth Rate Formula became law. The law contained health IT provisions related to current incentive programs and the need for interoperability. The Medicare Access and CHIP Reauthorization Act (H.R. 2) or MACRA was passed by the House of Representative on March 26, 2015 by a wide margin of 392-37 and by the Senate on April 14, 2015 by a vote of 92-8. Background The Sustainable Growth Rate (SGR) was created to control Medicare spending. Since 2003, Congress has spent $170 billion on short term patches to the SGR formula to prevent massive cuts in physician reimbursement, at times the imposing cut was more than 20 percent. The Medicare Access and CHIP Reauthorization Act (H.R. 2) outlines ways to improve fee-forservice Medicare and focus on quality instead of volume. The current estimated cost for the repeal of the SGR at $174.5 billion. With the addition of a two year extension of the Children's Health Insurance Program (CHIP), the law's cost rose to an estimated $213 billion, but only $70 billion was offset. The law also delays the implementation of the “two-midnight” rule through FY15 and extends other Medicare Programs for two years. Overall Reimbursement The bill indicates that Medicare physician reimbursement will increase by 0.5 percent each year from 2015-2019. The rates in 2019 will be maintained through 2025, while providing professionals with the opportunity to receive additional payment adjustments through the MIPS. In 2026 and subsequent years, professionals participating in APMs that meet certain criteria would receive annual updates of one percent, while all other professionals would receive annual updates of 0.5 percent. 1 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org Health IT Proposals Merit-Based Incentive Payment System (MIPS) In 2019, the Meaningful Use, Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM) programs will be combined into one incentive program called Merit-based Incentive Payment System (MIPS). MIPS will apply to: doctors of medicine or osteopathy doctors of dental surgery or dental medicine doctors of podiatric medicine doctors of optometry chiropractors physician assistants nurse practitioners clinical nurse specialists certified registered nurse anesthetists Other professionals paid under the physician fee schedule may be included in the MIPS beginning in 2021, provided there are viable performance metrics available. Professionals who treat few Medicare patients, as well as professionals who receive a significant portion of their revenues from eligible APM(s), will be excluded from the MIPS. Summary of MIPS Incentives / Penalties Program 2014-2017 Meaningful Use: Penalties: Meeting certain 1% in 2015 requirements in the use 2% in 2016 of certified EHR 3% in 2017 systems. 4% in 2018 5% in 2019 and beyond PQRS: 2% penalty for failure to report Incentivizes PQRS quality measures in 2017 professionals to report and beyond on quality of care measures. VBM: No penalties Adjusts payment based on quality and resource use in a budget-neutral manner. 2018-2023 MIPS: -Negative payment adjustments (performance score falls between 0 and ¼ of threshold) capped at: 4% in 2019 5% in 2020 7% in 2021 9% in 2022 -Some physicians will receive no adjustments if their performance score is equal to the threshold; -Positive payment adjustments: proportionally larger incentive payments up to a maximum of 3 times the annual cap for negative payment adjustments – total capped at $500 million/year each year 2019-2024 2 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org In 2019-2025, physician reimbursement will be based on a composite score from 0-100 based on performance in four categories: quality; resource use; EHR Meaningful Use; and clinical practice improvement activities. The score will be compared to a set threshold to determine penalties or bonuses. Eligible professionals (EPs) will only be scored on measures that apply to them and they will also be incentivized on improved performance from one year to the next. EPs will know the composite score they need to achieve to receive incentive payments or avoid penalties at the beginning of each performance period – the threshold will be determined by the mean or median of the composite performance scores for all MIPS EPs during a period prior to the performance period. See table for summary on negative, zero or positive payment adjustments under MIPS. Every year a list of quality measures for the forthcoming MIPS performance period will be published after the comment rulemaking process. This list of quality measures may include updates and modifications to previous quality measures. EPs will select which measures on the final list to report and be assessed on. Technical assistance will be provided for practices with less than 15 professionals to improve MIPS performance or to aid in the transition to APMs (with priority given to practices with low MIPS scores and those in low or underserved areas). $15 million will be allocated for quality measure development from 2015-2019. The law also renews funding for the National Quality Forum (NQF) for the review, endorsement and maintenance of quality and resource use measures through FY 2017. Alternative Payment Models (APM) Physicians will receive up to a five percent increase each year from 2019-2024 if a majority of their revenue comes from an APM (or APMs) or a patient centered medical home (PCMH). Participants need to receive at least 25 percent of their Medicare revenue through an APM in 2018-2019. In 2025 and subsequent years, professionals participating in APMs that meet certain criteria would receive annual updates of one percent, while all other professionals would receive annual updates of 0.5 percent. The policy also incentivizes participation in private-payer APMs. Interoperability By December 31, 2018, electronic health records must be interoperable. The law directs the Secretary to establish metrics to determine interoperability by July 1, 2016. If the nation has not met the Secretary’s metrics, HHS must submit a report to Congress before the end of 2019 with recommended actions the federal government should take to create widespread interoperability. The law prohibits providers from purposefully blocking information sharing with other EHR products, applicable within one year after the date of the enactment (April 2016). Hospitals and providers must also attest that they are not willfully blocking capability or interoperability of their certified EHR technology. 3 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org The law also directs the Secretary to conduct a report of the feasibility of establishing a mechanism for users to compare EHR vendor products, a website of surveyed user results and publicized reporting from vendors on their certified products. Questions & Comments should be directed to: Leslie Krigstein Interim Vice President of Public Policy [email protected] (202) 507-6158 (May 2015) 4 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org
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