January 1, 2017 marked the start of the first year of the Medicare Access and CHIP Reauthorization Act (MACRA) Quality Payment Program (QPP). More than halfway through the first performance year, many specialists are still trying to navigate participation, and one of the main questions is which payment track to pursue.
MACRA, which was signed into law in 2015, was established to accelerate efforts to reimburse clinicians based on quality of care, instead of volume of care. To comply with the law, physicians must enter one of the two QPP value-based payment tracks: MIPS or Advanced APMs.
Track 1: MIPS
Merit-Based Incentive Payment System (MIPS) is a payment system under which physicians receive positive, negative, or neutral payment adjustments for their performance in selected quality measures. The track requires reporting in four performance categories: Quality, Advancing Care Information through Health Information Technology, Clinical Practice Improvement Activities, and Resource Use. MIPS must be budget-neutral to Medicare on an annual basis, such that bonuses paid to relatively high performing physicians must be equally offset by penalties applied to relatively low performing physicians.
Track 2: Advanced APMs
The second track is Advanced Alternative Payment Models (APMs). For most specialists, participation in the upcoming next generation of Bundled Payments for Care Improvement (BPCI) will be the first opportunity to qualify for the Advanced APMs track. Participants who have sufficient revenue or patients in an Advanced APM will receive an automatic 5% payment bonus with the opportunity to earn even more if they achieve savings targets under BPCI.
The Next Opportunity For Track 2: BPCI Advanced
It is important to note the two-year lag under both QPP payment tracks such that clinician reimbursement in 2019, MACRA’s first payment year, is based on performance during 2017. To qualify for the Advanced APMs track in payment year 2020, providers must begin participating in an Advanced APM in 2018.
With the MACRA QPP’s second payment year fast approaching, providers should think strategically about which track they should pursue. Of the two tracks, we at Archway believe the Advanced APM track is more advantageous for specialty-focused providers. While physicians are forced to accept downside risk under an APM arrangement, there are clear benefits: better access to performance data through the Center for Medicare & Medicaid Innovation (CMMI) to implement care improvement initiatives, the opportunity to receive a 5% lump sum bonus under MACRA (regardless of performance in the Advanced APM) and avoidance of downside risk and additional quality reporting requirements under MIPS. Conversely, MIPS offers limited upside potential due to the forced-ranking mechanism applied by CMS to achieve budget neutrality, as well as a diminished incentive pool resulting from broadened MIPS exclusionary criteria.
At Archway, we believe qualifying for the Advanced APMs track though participation in the next generation BPCI program is not only the better option under MACRA’s QPP, it’s a better business solution. Bundled payments can help grow your practice, and Archway is the partner to help you navigate these bundled payment programs.