MACRA Delay: Does it even matter?

The Centers for Medicare & Medicaid Services (CMS) proposed the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) in late April, 2016. This release announced a fundamental overhaul of physician payment methodologies from a model reimbursing each individual service (office visit, surgery, lab test, imaging service, etc.) to a system rewarding “Value,” and, “Quality.” The proposed implementation date is set for January 1, 2017 though nearly half of U.S. physicians are aware of MACRA’s implications. Similarly, 80% of physicians surveyed expect MACRA will spur further consolidation. Interestingly only one in four physicians opt to seek employment whereas 75% would prefer to join a Clinical Integration Network.

As administrators and physicians alike prepare for MACRA’s upheaval, many anticipate some flexibility in CMS’ proposed start date as the final rule, to be released in November, only allows two months to prepare for either Merit Incentive-Based Payment System (MIPS) or the significantly more exclusive world of Advanced Alternative Payment Models (APMs).

With the recent completion of CMS’ listening tour, Andy Slavit, CMS’ Acting Administrator, is continually cited hinting towards the delay of MACRA’s first reporting year. Though many, if not all, physician-advocacy groups such as the American Academy of Family Physicians (AAFP) and the Medical Group Management Association (MGMA) are advocating for a delayed start date, it is wise to ensure your organization is preparing a reporting infrastructure and network based upon MACRA’s initiatives.

Theoretically, CMS’ most obvious options in terms of a widely encouraged public perspective that MACRA needs to be delayed are:

• Delay the start date by six months to July 1, 2017 and implement an initial six-month reporting period for to determine CY 2019 payments.
• Delay the start date by one year, with a possible “interim” final rule year to receive additional provider feedback considering the massive looming redistribution of healthcare spending to come
• Institute a “Dry-Run” year in which providers’ will report in CY 2017 but face no penalties or rewards in CY 2019.
• Ignore public pressure and face the political ramifications of burning bridges with essentially all major provider organizations and continue the implementation on July 1, 2017 as currently proposed.

Regardless of CMS’ external pressures on your organization, it is wise to continue internal preparations. If the law is delayed, those organizations that ignore MACRA’s implications will only see their comparative MIPS scores fall even farther behind those organizations that have clinically integrated, built population health infrastructure, and organized their quality reporting methodologies. It’s moments like these that we should think of Yogi Berra because, “The future ain’t what it used to be.”