Even though the final MACRA rule is not expected until November 1, 2016, you would be well advised to start putting an action plan in place now. As proposed, the first performance year begins on January 1, 2017, a mere 2 months after the expected release of the Final Rule—you won’t have sufficient time to prepare if you wait until then. Yes, CMS has hinted about a possible delay or a shortened reporting period (in response to numerous concerns expressed in the 4,000 comments to the proposed rule), but you cannot bank on that until it is finalized. There are things you can do to start planning your strategy and improve your chances of success when this first regulatory foray into value-based payment begins:
- Focus on 2016 PQRS reporting: Quality reporting carries a 50% weighting next year, which makes it the most important of the 4 MIPs performance targets, (the others being Advancing Care Information, aka MU; Clinical Practice Improvement Activities; and Resource use, aka cost). Take advantage of the next 4 months to improve your quality measure workflow and reporting.
- Think about whether to report MIPS as individual physicians or as a group: It’s important to look at your practice’s current MU and PQRS performance as a predictor of which option might be more beneficial. You may already be reporting PQRS as a GPRO—success here makes a strong argument for reporting all categories as a group. (Remember, as proposed, you must report consistently across all 4 MIPS categories.)
- Develop workflows to support success: Identify the ACI patient engagement and health information exchange (HIE) measures that are of most interest or relevance to your practice. Analyze and try to enhance the workflows that support these measures. Ask your EHR vendor for a professional services evaluation—they may be able to offer assistance in this regard.
- Review the list of Clinical Practice Improvement Activities: Review the list provided in Table H of the Proposed Rule. Are there activities that fit your practice or possibly some that you were considering, even before MACRA?
- Evaluate your current technology resources: Is your EHR up to the job—or is it killing your productivity, particularly when you use it to meet the government requirements? If you are not satisfied, now is a good time implement new technology.
The most important step to take now and in the coming months is to keep yourself educated and up to date as the regulations evolve and the start date approaches, (But you clearly know that, since you’re reading this post!) On cms.gov, you will find Quality Payment Program Resources pages. You can also consult your professional societies/academies for specialty-specific guidance or reach out to your EHR vendor for training. I invite you to watch (or watch again) my webinar titled, “MACRA/MIPS: 962 Pages in 30 Minutes”, which is available on demand.
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