MACRA Insights for Clinics and ACOs

Practical Implicationson 2020 MIPS Proposed Rule

 fedreg-first-issueThis year, CMS published its shortest set of updates to MACRA yet.  Of course, "short" is a relative term and there are only 108 pages of Federal Register content to contemplate.  After a rather dramatic set of 2019 changes, we might be starting to see stability in the world of MACRA ... at least for next season.  Here is what I see as a handful of the things that will drive new activity in 2020 (no ranking is implied in my sequencing).  

  1. CMS wants providers to analyze MIPS scores more frequently than just at year end. In fact, they are likely to require that Clinical Registries and QCDRs provide "more than four" feedback sessions per year to their clients, or submit reports to CMS as to why they did not.  
  2. ACO member clinics may be able to submit their own quality measures, rather than rely on the ACO-generated measures.  In so doing, a clinic would receive a substantial bonus of 50 (out of 100) points.  This almost guarantees quality scores of 100% for most ACO member clinics. 
  3. Transitional performance thresholds are starting to phase out, for MIPS overall performance and exceptional performance.  The upshot of this is that more money should be working its way into the program, for high performers. 

There are a lot of other, less impactful adjustments, but the common thread across these three key points is an emerging maturity to the program.  With more money available and higher competition, providers should begin to take MACRA more seriously with formal programs of analyzing their MIPS performance in order to avoid leaving money on the table.  

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