MACRA Final Rule: How Do I Know Where I Stand?

A big news item in healthcare is CMS’ recent release of the MACRA Final Rule, which articulates CMS’ future direction for Medicare Part B. With the Final Rule, CMS makes clear the following strategic objectives in developing MACRA’s new Quality Payment Program (QPP):

CMS notes in the Final Rule that unifying the QPP is best accomplished by linking the four pillars of MIPS: quality, clinical practice improvement activities, advancing care information, and resource use, with emphasis on improving the quality of patient care. CMS emphasizes that accurate, timely, and actionable feedback is a bedrock component of the QPP. Yet the Final Rule is not the final word, with more pronouncements and updates still to come, including important changes to processes around clinician feedback in the MIPS program.

A prime challenge with feedback is the timeliness with which feedback is given and whether it is received quickly enough for the organization to respond with changes and improvements. Based on comments received, CMS noted in the Final Rule that it will continue exploring opportunities with which to provide more frequent feedback.

In accordance with MACRA, CMS is required to provide MIPS clinicians with timely, confidential feedback on quality and cost performance beginning July 1, 2017, a date prior to the deadline for MIPS data. Quality and Cost Reports (QRURs) from the current Physician Feedback Program are a good starting point for performance feedback. The Annual 2015 QRUR, released on September 26, 2016, is the first MIPS performance feedback report required under the law, indicating quality and cost performance relative to national benchmarks. However, QRURs will not be provided after December 31, 2017, as CMS plans to use a different format for future years and will engage with clinicians to be certain feedback reports are user-friendly and contain relevant data. CMS will also continue to work with stakeholders to find the best ways to add feedback from the clinical practice improvement activities and advancing care information performance categories.

Because current performance feedback is produced at the Taxpayer Identification Number (TIN) level, this feedback is unlikely to contain enough detail for clinicians who will be measured at the TIN/NPI number for MIPS purposes. To address this, CMS will provide as much feedback as possible to clinicians at the individual level prior to the 2018 performance period, such as claims-based outcomes measures and cost data.

Clearly, there is work to be done. The fact that unanswered questions exist should not mean delaying work on clinical improvement efforts, seeking efficiencies, reducing redundancies, and eliminating unnecessary costs. These need to occur regardless of the timing of feedback tools. Moreover, using existing data—including QRURs—to measure current performance outweighs waiting until CMS produces MIPS feedback reports.

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