The California Medical Association (CMA) recently submitted comments on proposed 2018 changes to the Medicare Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Though not perfect, CMA is pleased that the Centers for Medicare and Medicaid Services (CMS) has listened to physician feedback and has made changes that will significantly reduce the administrative burdens on physicians, particularly for small and rural practices. We appreciate the agency’s responsiveness to many of our concerns about the ability of physicians to successfully participate in the QPP. 

Under the proposed rule, 2018 will be another transition year like 2017. This means that physicians who report only one quality measure in 2018 can avoid all penalties in 2020. CMS estimates that under the proposed 2018 MACRA rule, 94 percent of physicians will earn either a positive or neutral payment adjustment in 2020 for the 2018 reporting year. Thirty-seven percent of physicians are expected to be exempt because of the low-volume threshold. The proposal would also allow virtual groups and provide bonus points for physicians treating complex patients.

CMA is urging CMS to make additional changes to further reduce administrative burdens while allowing physicians to be innovative and improve care. Among the changes CMA is seeking are a reduction in the number of electronic health record (EHR) measures; expanding the adjustments for complex patients; removing the requirement to report all payer data; and exempting physicians within five years of retirement. CMA is also urging CMS to hold EHR vendors more accountable, particularly for interoperability.

Major highlights of the proposed rule include:

• Continues 2018 as a “Pick Your Pace” transition year, during which physicians can easily avoid all penalties.

• Provides additional accommodations for small and rural practices, including automatic bonus points for small practices.

• Expands the total exemption to physicians with $90,000 or less in Medicare Part B allowed charges or 200 or fewer Medicare patients.

• Allows virtual groups to organize and help small practices pool resources to report successfully.

• Provides bonus points for physicians treating complex patients, including dual-eligible patients.

• The flawed “resource use” (physician cost) category will not count again for the 2018 reporting year.

• Continues to allow use of the 2014 edition of Certified Electronic Health Record Technology.

• Provides new Advancing Care Information (EHR) hardship exemptions for physicians in small practices.

• Provides exemptions from all Advancing Care Information (EHR) requirements if a physician’s EHR is decertified.

• Provides new bonus points for Advancing Care Information (EHR) requirements.

• Permits physicians to continue to report modified stage 2 meaningful use measures in 2018 instead of new stage 3 measures.

• Provides new options to use facility-based scoring for facility-based physicians who provide more than 75 percent of their services in an in-patient setting or through the emergency department.

• For Alternative Payment Models (APM), extends the current, more reasonable nominal financial risk requirement of 8 percent of total Medicare revenue for two more years.

• Reduces the financial risk requirements for APM medical homes.

• Reduces reporting burden for the Merit-Based Incentive Payment System and APMs.

For more details on CMA’s proposed MACRA changes, see CMA’s full comments, which are based on the recommendations of our MACRA Technical Advisory Committee.

CMA will be working closely with the American Medical Association (AMA) and CMS to monitor the QPP’s effect on physician practices, the physician-patient relationship and access to care.

CMA MACRA Resource Center

To help physicians understand the MACRA payment reforms and prepare for the transition, CMA has published a MACRA resource page. There, you will find an overview of MACRA and a comprehensive list of tools, resources and information from CMA, AMA and CMS.

Free MACRA assistance for California physicians

The Health Services Advisory Group, in partnership with the California Health Information Partnership & Services Organization (CalHIPSO), is providing no-cost technical assistance to physician offices in California to help them prepare for and participate in the MACRA QPP. CalHIPSO is also hosting a CMA webinar on September 20 to answer physician questions about MACRA reporting.