Chair, ACG National Affairs
This week, the Centers for Medicare and Medicaid Services (CMS) announced that the Agency will ease reporting restrictions and potential payment cuts under Medicare’s new reimbursement law. As you know, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Medicare sustainable growth rate (SGR) formula and created a new reimbursement system beginning 2019. However, CMS will use CY 2017 as the reporting year to determine your 2019 payment.
While CMS did announce some help in this transition, the Agency also stated that it would release the final rule by November 1, 2016. To help ACG members and others avoid reimbursement cuts in 2019, CMS announced the following reporting options for CY 2017:
First Option: The Test Option
CMS stated that as long as ACG members “submit some data” for MIPS after January 1, 2017, they will avoid a payment cut. According to CMS, “this first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.”
Second Option: Partial Year Participation
CMS stated that ACG members may choose to submit MIPS information for a portion of CY 2017 and could still qualify for a “small positive” payment bonus.
Third Option: Full Speed Ahead
For ACG members that are ready to go on January 1, 2017, your “first performance period” would begin on January 1, 2017, and you could qualify for a “modest bonus,” according to CMS’ announcement.**
** Wait, “modest bonus”? Remember, ACG has informed members that this MIPS program requires “budget neutrality,” or others to fail first in order for you to get a bonus….. It is difficult to get a good bonus if few providers are subject to cuts in 2019 (CY 2017 being the performance year). However, this option may help ACG members fall into the “exceptional performance bonus” category of MIPS, which is not subject to budget neutrality rules.
Fourth Option: Participate in an Advanced Alternative Payment Model
CMS also announced that joining an Advanced Alternative Payment Model, “such as Medicare Shared Savings Track 2 or 3 in 2017” is another option for ACG members. If ACG members receive enough Medicare payments or see the required Medicare patients through the Advanced Alternative Payment Model in 2017, then members would qualify for a 5% bonus in 2019.
Why the Change?
This announcement comes on the heels of a bipartisan congressional letter to CMS this week, urging CMS to implement greater flexibility in MACRA reporting requirements. ACG welcomes this news, but continues to urge CMS to delay MACRA even further. As noted by CMS in the announcement, the final rule will be released by “November 1, 2016.” This affords ACG members and GI practices roughly two months to understand the details, and then be able to compare and consider these reporting options outlined by CMS this week. Thus, ACG continues to advocate for more time to transition into MACRA, especially for smaller GI practices.
Whitfield L. Knapple, MD, FACG
Chair, ACG National Affairs Committee