Observations Regarding a Possible Delay of MIPS/MACRA

August 30th, 2016 by

CMS is required to published the MACRA final rule by November 1, 2016. In the meantime, we are frequently asked about a possible delay or shortening of the first performance period of MACRA/MIPS, currently proposed to be starting January 1, 2017. Acting CMS Administrator Andy Slavitt left open the possibility during a U.S. Senate Committee on Finance hearing on July 13th. 

Here are some things to consider:

1. Postponing the first payment year (CY2019) requires Congress to override 92-8 Senate and 392-37 House approval of the MACRA legislation. It may be difficult for Congress to take action in light of the presidential election year and competing legislative priorities for the remainder of this year.  

2. A shortened first MIPS performance period does not affect the size of the CY2019 payment adjustment. The legislation clearly decouples the length of the performance period from that of the payment adjustment period (one year worth of payments in CY2019).

3. If the first payment year remains CY2019 (per point 1 above), then a CY2017 MIPS Quality category performance period will be difficult to delay due to the time needed by CMS to collect quality data, complete the score calculations, and distribute provider feedback reports. MACRA inherits many of the quality reporting methods from the PQRS program and used for the Value-Based Modifier. The Value-Based Modifier quality score calculation process has historically taken CMS about nine months past the end of the performance period and three months prior to the start of the payment year to complete. If the end of the first MIPS quality category performance period were to extend past the end of CY2017, then CMS may find it difficult to complete the calculations in time to be applied to a CY2019 payment year, as mandated by the MACRA legislation. 

4. For MU, CMS has implemented 90-day performance periods in the past, making doing so for ACI likely more feasible than for other MIPS categories such as quality. In fact, CMS has proposed a 90-day MU performance period for CY2016 which is currently in the process of being finalized. 

5. Given that the MACRA legislation sunsets PQRS, Value-Based Modifier, and Medicare MU programs in favor of MIPS, a delay of all MIPS categories would create a period when the vast majority of Part B clinicians would not be subject to any Medicare value-based performance measurement. This would run counter to CMS’ stated objective of tying 90% of all fee-for-service payments to quality and value metrics. 

6. Few organizations are slowing preparations for MIPS despite the potential delay or shortening of the first performance period – it’s too complex and impactful. Plus, a delay applying to all MIPS eligible clinicians would net all clinicians the same advantage within the competitive scoring system where every point translates into dollars. For more information on preparing for MIPS, download this informative white paper

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