What Is the ACR Doing About MACRA, MIPS, and APMs?

A Resident’s View

MACRA

If you’re wondering what the ACR is doing to position radiology for success in the changing health care system, I’ve got an answer for you: A lot.

 On April 16, 2015, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law. This legislation changes reimbursement from the current system of fee-for-service (FFS) to a fee-for-value system. The ACR has been working tirelessly to prepare for the change and had been developing quality metrics for years prior to the passage of MACRA. Here’s what residents and fellows need to know about MACRA.

MACRA replaces the Medicare Sustainable Growth Rate (SGR) methodology for updates to the physician fee schedule (which determines how much physicians are paid for each procedure). The legislation mandates fixed yearly increases of 0.5 percent until 2019 and implements a new system of incentive payments based on quality metrics and risk sharing. The legislation describes two incentive-based payment mechanisms – the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). FFS will continue, but incentive payments from CMS will no longer be available to those that participate in strict FFS models.

MIPS can be described as fee-for-service plus links to quality and value, based on the documentation available from CMS, the federally funded CMS Alliance to Modernize Healthcare, and the Health Care Payment Learning & Action Network (a CMS advisory group). Under MACRA, a number of existing programs will be combined, including the current Physician Quality Report System, the Value-Based Payment Modifier, and the Medicare Electronic Health Records Incentive Program (a.k.a. the meaningful use program). However, the quality metrics captured by these programs will continue to be captured in MIPS and will contribute to the MIPS composite score.

Each provider participating in MIPS will receive a composite performance score based on four performance categories: quality, resource use, clinical practice-improvement activities, and meaningful use of EHRs. The individual’s score will then be compared to a threshold score and a payment adjustment — positive, neutral, or negative — will be assessed on reimbursement for the service. The ACR has been working to ensure that appropriate radiology-specific quality measures will be used to calculate the MIPS composite score for radiologists. Additionally, radiologists who engage in Imaging 3.0 practices will have a head start in the upcoming MIPS/APM implementation.

APMs encompass payment models in which payment is linked to “effective management of a segment of the population or an episode of care,” AKA population-based payment. Payment can be based on delivery of services or capitation depending on the type of APM. Furthermore, shared saving and shared risk are components of the new APM structure. Current accountable care organizations (ACOs) fall under the APM model.

The details of MIPS and APMs are still under development. In late September 2015, CMS released a request for information asking stakeholders to comment on MIPS and APMs. In response, the ACR convened a workgroup at ACR Headquarters to systemically review and generate a response to the CMS request.

CMS has yet to issue the final rule governing the new MIPS/APMs reimbursement system, but ACR leaders, physician volunteers, and staff are working to ensure radiology-appropriate quality metrics exist in the new system so radiologists can best serve their patients.

Additional resources:

Reimbursement Revolution by Geraldine B. McGinty, MD, MBA, FACR, chair of the ACR Commission on Economics

ACR resource page for Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APM)

MACRA webinar

The original request for information from CMS regarding MIPS/APMs and the ACR response.

H.R.2 - Medicare Access and CHIP Reauthorization Act of 2015

The CMS page on the Merit-Based Incentive Payment System (MIPS) & Alternative Payment Models (APMs)

CMS information page for the Health Care Payment Learning and Action Network

Health Care Payment Learning and Action Network (HCPLAN)


By Colin Segovis, MD, PhD (@colinsegovis), Moorefield Fellow in Economics & Health Policy, RFS secretary, and resident at Wake Forest University

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