With MACRA set to begin on January 1, 2017, the Centers for Medicare & Medicaid Services (CMS) announced this week more flexibility for physicians as it relates to complying with the physician quality payment program.

The update announced this week now allows for some easing into the program that the original rules did not include:

  • Option 1: Physicians following the MIPS pathway can now test the program and submit some data to the program and avoid a negative payment adjustment. This option allows physicians to ensure their systems are working for compliance in future years 2018 and 2019. Physicians choosing this option would avoid a negative payment adjustment.
  • Option 2: Physicians following the MIPS pathway can participate for a partial year. A slight positive payment adjustment could be awarded for physician data submitted after January 1, 2017.
  • Option 3: Participate in the MIPS pathway for the full calendar year and physicians may receive a more modest positive payment adjustment. Many physician practices have been preparing for these new quality measures and may be ready to participate fully on January 1, 2017.
  • Option 4: For those physicians participating in an Alternative Payment Model (APM), the update allows for participation in an Advanced APM such as Medicare Shared Savings Track 2 or 3 in 2017 instead of reporting quality data and other information under the MIPS pathway.

The four options will be described in more detail in the final rule to be issued by November 1, 2016; however, this announcement only affects reporting requirements for the program’s first year. Physician practices should continue to plan towards a full implementation of MACRA reporting guidelines and make sure processes are in place ahead of time to allow for an easier transition.

For more information, contact your Dean Dorton advisor or:

Adam Shewmaker, ashewmaker@ddafhealthcare.com

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Porter Roberts, proberts@deandorton.com

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