MACRA Year 2 Moving out of the Transition Period and Into Reality February 16, 2018

Transcription

1 MACRA ear 2 Moving out of the Transition Period and Into Reality February 16, 2018

2 February 16, 2018: Where are we in MACRA implementation? The 2018 performance year is underway. Cost will take effect for the first time, accounting for 1 of the MIPS 1performance score. Clinicians face a March deadline to report MIPS 2data for The President on February 9, 2018, signed into law a bill that includes targeted technical changes to MIPS. The first performance year under the All-Payer Combination Option will begin 4January 1, Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 2

3 Payment updates under MACRA With the repeal of the Sustainable Growth Rate (SGR) formula, MACRA sets updates to the Medicare physician fee schedule (PFS) for all years in the future. The Bipartisan Budget Act (BBA) of 2018 made one change fee schedule update reduced by BBA from 0.5% to 0.25% APM QPs 2026+: 0.75% PFS Updates 2016: 0.5% 2017: 0.5% 2018: 0.5% 2019: 0.25% 2020: 2021: 2022: 2023: 2024: 2025: 2026+: 0.25% on-qps Under MACRA s Quality Payment Program (QPP), clinicians have two distinct paths for payments under the PFS going forward: Advanced Alternative Payment Models (APMs) Risk-based, care coordination models For Qualifying Participants (QPs), temporary bonuses from (5% of Medicare PFS payments) Increasing thresholds for QP status over time All-Payer Combination Option begins in performance year 2019 Merit-based Incentive Payment System (MIPS) Consolidates Meaningful Use, Physician Quality Reporting System (PQRS) and Value-based Modifier Budget-neutral payment adjustments based on clinician performance +/-4% for 2019, progressively increasing to +/- 9% for 2021 and subsequent years For 2017, it is expected that approximately 85% of providers eligible for MACRA will have participated in MIPS Source: Public Law (April 16, 2015); Public Law (February 9, 2018) Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 3

4 The Quality Payment Program by the numbers The Centers for Medicare & Medicaid Services (CMS) estimates that MIPS payment adjustments for 2019 will be +/- $118 million, while APM incentives will be between $675 million and $900 million for the 2020 Payment ear. Leadership will play critical roles as organizations engage with clinicians with different incentives under the QPP. Projected participation in the Quality Payment Program for the 2018 performance year 81, ,347 1,548,022 70,732 17, ,700 All Medicare clinicians billing Part B ewly enrolled clinicians Low-volume threshold clinicians APM Qualifying Participants (QPs) Excluded clinicians who previously submitted measures groups under 2016 PQRS MIPS eligible clinicians Exempt from MIPS Reporting ote: CMS counts clinicians as unique combinations of Tax Identification umber (TI) and ational Provider Identifier (PI). Source: Final Rule with Comment Period on Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive (ovember 16, 2017). Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 4

5 MIPS Scoring for Performance ears The Bipartisan Budget Act of 2018 gives the HHS Secretary until 2022 to increase the weight of the MIPS Cost measure from 1 to 3 of the overall MIPS composite score. Components of MIPS Score in Performance ears For 2019 through 2021, the HHS Secretary has the authority to set the weight of the Cost category between 1 and 3, and adjust the weight of the Quality category proportionately At least 1 At least 1 At least 1 15% 15% 15% 15% 15% 15% 25% 25% 25% 25% 25% 25% Advancing Care Information Improvement Activities Cost Quality Source: Public Law (April 16, 2015); Public Law (February 9, 2018) Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 5

6 MIPS Performance Threshold for 2018 The Bipartisan Budget Act of 2018 gives the HHS Secretary the option of setting the MIPS threshold score at less than the mathematic mean of MIPS performance scores through performance year For 2018, CMS projects that fewer than 3% of MIPS eligible clinicians will receive negative payment adjustments For 2018, CMS projects that more than 97% of MIPS eligible clinicians will receive positive or neutral payment adjustments, with nearly 75% qualifying for a positive payment adjustment with exceptional payment adjustment. Source: Final Rule with Comment Period on Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive (ovember 16, 2017). Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 6

7 Current qualifying Medicare Advanced APMs Requirements for Advanced APMs 1. Bundled Payments for Care Improvement-Advanced (BPCI-Advanced) 2. Medicare ACO Track 1+ [downside risk] Available for Medicare Shared Savings Program (MSSP) Track 2 [downside risk] 4. Medicare Shared Savings Program (MSSP) Track 3 [downside risk] 5. ext Generation Accountable Care Organization (ACO) Model 6. Comprehensive Primary Care Plus (CPC+) 7. Comprehensive End-Stage Renal Disease (ESRD) Care (CEC) - Large Dialysis Organization (LDO) arrangement 8. Comprehensive ESRD Care Model (non-ldo arrangement) 9. Oncology Care Model (OCM) two-sided risk arrangement 10. Comprehensive Care for Joint Replacement (CJR)* Bundle 11. Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model) Source: Public Law (April 16, 2015), CMS, Medicare Program; Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR), July 2016 Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 7

8 Getting into the advanced APM track and staying there The threshold for QP status in advanced APMs increases dramatically in just 5 years. Many organizations are looking to the Other Payer Advanced APM option beginning in the 2019 performance year QP Payment Amount Thresholds QP Patient Count Thresholds % % Performance year % 25% 5 35% Performance year Qualifying participant (QP) Partial qualifying participant Other payer model begins Source: Public Law (April 16, 2015) Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 8

9 Qualifying Participant (QP) Determination Tree for Medicare, All Payer Combination Options Medicare Option Performance years Is Medicare Threshold Score >= 2? Is >= 25%? MIPS EP QP Partial QP All-Payer Combination Option Performance years Is Medicare >= 5? Is Medicare >= 75%? Performance years 2023 and later QP Is Medicare >= 25%? QP Is Medicare >= 25%? Is All-Payer >= 5? Is Medicare >= 2? Is All-Payer >= 75%? Is Medicare >= 2? Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 9 QP Is All-Payer Threshold Score >= 4 OR is Medicare Threshold Score >= 4? MIPS EP QP Is All-Payer Threshold Score >= 5 OR is Medicare Threshold Score >= 5? MIPS EP Partial QP MIPS EP QP MIPS EP

10 Key Dates under the All-Payer Combination Option January 2018 February 2018 April 2018 May 2018 June 2018 September 2018 January 2019 Draft Medicare Advantage Call Letter January 1 - April 1: Submission period for states to submit Medicaid arrangements to CMS to be considered Other Payer AAPMs Final Medicare Advantage Call Letter January June: First CMS Multi-payer Model submission period April June: Submission period for Medicare Advantage plans to be considered Other Payer AAPMs // // CMS posts list of Other Payer APMs in Medicaid and MA for 2019 performance year Beginning of first performance year under All Payer Combination Option Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 10

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12 Daniel Esquibel Senior Manager Regulatory Services, Life Sciences & Health Care Profile Daniel Esquibel th Street W, Suite 400 Washington, DC, Phone: As used in this document, Deloitte Advisory means Deloitte & Touche LLP, which provides audit and enterprise risk services; Deloitte Financial Advisory Services LLP, which provides forensic, dispute, and other consulting services; and its affiliate, Deloitte Transactions and Business Analytics LLP, which provides a wide range of advisory and analytics services. Deloitte Transactions and Business Analytics LLP is not a certified public accounting firm. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Daniel is a Deloitte Advisory Senior Manager at Deloitte & Touche LLP. Building off of more than 17 years of experience in the health care industry, Daniel works with health care providers, health plans, investors and other stakeholders to identify factors that will drive health care in the future. He helps stakeholders evaluate and plan for strategic risks and opportunities based on insights and analysis of government and private sector data; market trends; and political, legislative and regulatory issues affecting the health care industry. Daniel is actively monitoring the legislative and regulatory agenda for health care and life sciences for 2018, including implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the 21 st Century Cures Act, and the Tax Cuts and Jobs Act of In addition, Daniel is tracking regulatory changes to Medicaid, Medicare Advantage, the Program for All-Inclusive Care for the Elderly (PACE), as well as policies from the Center for Medicare and Medicaid Innovation (CMMI). Prior to joining Deloitte Advisory, Daniel spent five years at a global professional services firm advising organizations on the implementation of the Affordable Care Act (ACA), including issues related to eligibility for premium tax credits and Medicaid, the employer mandate, and health insurance market reforms. He authored detailed analyses of the major ACA regulations from the Department of Health and Human Services, the Department of the Treasury, the Internal Revenue Service, and the Department of Labor. Daniel s career in professional services builds off of 10 years of experience in strategic research and policy analysis at a research, technology, and consulting firm focused on the health care industry. Daniel regularly speaks and writes on health care regulatory and legislative issues. Education B.A., History - University of Pennsylvania Copyright 2018 Deloitte Development LLC. All rights reserved. Medicare Access and CHIP Reauthorization Act 12

13 About Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see to learn more about our global network of member firms. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Copyright 2017 Deloitte Development LLC. All rights reserved.