MACRA: One Year On
MACRA’s first anniversary is upon us. Where are we now?
It’s hard to believe that a year has elapsed since the overwhelmingly bipartisan passage of the MACRA (Medicare Access and CHIP Reauthorization Act) legislation that repealed the Sustainable Growth Formula and set us on an accelerated trajectory toward value-based payments.
If you haven’t had a chance to learn the new alphabet of value-based payments, from MIPS to CPI, I highly recommend an excellent webinar created by ACR economics experts Ezequiel Silva III, MD, FACR, and Gregory N. Nicola, MD.
With the new payment incentives scheduled to go live in 2019 based on performance for 2017, there is less time than you might think for Medicare to put in place the various metrics and performance thresholds. Bear in mind that everything Medicare does has to be published in a federal rule with appropriate time for public comment. Additionally, for measures to be included in CMS value-based payment programs, CMS must have potential measures reviewed by the National Quality Forum–convened Measures Application Partnership (MAP) before publishing measures in the proposed rule. The MAP reviews measures and makes recommendations to CMS in a December–February time-frame, just prior to the rulemaking process.
We’ve been very busy at the ACR making sure that radiologists have the maximum opportunity to deliver high-value care to their patients and be rewarded for doing so, whether we choose to participate in the more fee-for-service system of MIPS or in an alternative payment model such as an accountable care organization. Immediately after the legislation passed, we began assembling a workgroup and establishing a process to respond to what we knew would be multiple requests for information from CMS. The agency was candid in requesting the help of specialty physicians to craft meaningful metrics, and we were not about to let that opportunity pass.
CMS’ MIPS program has four components. It rolls up the existing value- or quality-based programs (the Physician Quality Reporting System, meaningful use, and the value-based modifier) and introduces a new program: Clinical Practice Improvement. We recognized that our best effort would entail close collaboration across disciplines, and the ACR workgroup was therefore assembled to include representatives from quality and safety, informatics, economics, and the new Commission on Patient- and Family-Centered Care. Bibb Allen Jr., MD, FACR, chair of the ACR Board of Chancellors graciously agreed to be our executive sponsor. Very importantly, we set a mission for our effort:
To create meaningful opportunities for radiologists to participate in imminent value-based payment models that positively impact patient care at equal or lower costs. This effort includes the development of models and measures that improve and grow the entire profession to the benefit of patients.
At a face-to-face meeting at ACR headquarters, we framed our strategy and basic principles and used those to respond to the first of CMS’ requests for information. Underpinning our process was a survey of the membership to take a pulse on the types of payment models radiologists are subject to (no surprise, it’s largely still fee for service), as well as some cross-commission education for the workgroup members. For example, those of us in economics need to know exactly how the ACR crafts registries in order to shape policy that incentivizes registry participation.
In November, we submitted a 41-page response to CMS. A number of additional requests have been issued around topics like definition of episodes and metrics development. The foundational work of the group has permitted us to deliver coherent responses each time. We have also engaged with the CMS staff leading this process. Recognizing that they are being deluged with responses, we have tried to crystallize for them the key points. Throughout the process, we’ve built on the collaborative relationships we have developed over the past few years around initiatives like lung cancer screening and clinical decision support. We work with a number of health policy consultants who bring a valuable external perspective, and we’ve been encouraged to hear that the ACR response has been ahead of those from other societies.
Those of us in economics look to the critical work of James M. Moorefield, MD, FACR, to establish the relative value scale for radiology. I can only hope that we can serve our patients and our profession as well as he and his ACR colleagues did. The collaboration of our workgroup members and our shared commitment to shaping payment policy to the benefit of our patients makes me optimistic that we’re on the right track.
By Geraldine B. McGinty, MD, MBA, FACR, Chair