In April 2015, Congress passed the landmark bipartisan legislation MACRA (Medicare Access and CHIP Reauthorization Act) which introduced two new payment tracks for physicians and guidelines to move compensation from a fee-to-service model to a value-based one. Ultimately, the legislation is intended to improve the quality of patient care in America by driving health care payment and delivery system reform for clinicians.
Now with the election of President Trump, a new variable has been introduced; how this shift in leadership affects the healthcare landscape is yet to be determined. We do know that both parties have supported patient-centered care and outcomes since 2003’s Medical Modernization Act through to the MACRA legislation, providing some assurance that many of the initiatives outlined in these pieces of legislation will continue to be upheld and likely rolled out through 2017 and beyond. Thus, it is still vital that we examine the impact of MACRA on healthcare delivery and specifically, radiology.
The impact of MACRA on radiology centers, hospitals and radiologists is unique. Several components of the legislation will affect radiology, and more specifically, image sharing. How you prepare for this legislation can affect the course your business takes.
Radiologists have raised concerns regarding the new payment models given their status as non-patient facing clinicians. How will MIPS performance metrics take this into account? The Centers for Medicaid and Medicare Services (CMS) responded with a new definition for non-patient facing clinicians. Based on an analysis of HCPCS codes, CMS has decided that any individual or group that bills 25 or fewer patient facing encounters in one year qualifies as a Non Patient facing Merit-based Incentive Payment System (MIPS) eligible clinician. In addition, they’ve redefined “patient facing encounters” and listed new face-to-face encounter codes on their website. They estimate that 25% of MIPS eligible clinicians will be non-patient facing. Recognizing this as a separate category helps ensure radiologists will be compensated regardless of their indirect relationship to patients — as a clinician who furnishes care on the orders of another physician.
The radiology-related performance metrics outlined in the MACRA proposed rule are consistent with areas radiology practitioners have been emphasizing recently:
- Radiation dose management – Several performance metrics address efforts to minimize the amount of radiation patients receive; for example, the documentation of radiation doses exposure and participation a radiation dose index registry.
- Recommendation follow up – In order to address concern over radiologists’ low rate of follow up, the CMS has established requirements around follow up to imaging screening exams and incidental findings.
- External image sharing– Providers are encouraged by CMS to make DICOM images available to external health care facilities. In addition, in another effort to help reduce patient exposure to radiation, the CMS is encouraging facilities to search for patient DICOM images prior to ordering another imaging exam as they might not be necessary.
However, radiologists, hospitals and imaging centers need to proactively prepare for these changes. In order to ensure regulatory requirements are met and your organization is transitioned to one of the two new quality payment models: the MIPS and the Alternative Payment Model (APMs), you need to be ready.
Compliance with these new billing and reporting rules is important to ensuring profitability as focus shifts from volume to value. McKesson Medical Imaging Consulting is uniquely positioned to help with this transition and to evaluate and advise radiologists, departments or clinics on areas that will affect the MACRA rollout namely, communications, payor analysis, clinician structure and historical PQRS performance.
Significant numbers of US Physicians are woefully unfamiliar with MACRA according to a Deloitte survey. To mince words, this ignorance may have a negative impact on their bottom line; future reimbursements, under the new model, are based on reporting from last September 2015 to August 2016. To avoid this, communication and education are key. Organizations need to kick start education campaigns using webinars, presentations, emails, etc. to inform themselves and their team about MACRA. If changes are introduced incrementally, in digestible ‘chunks’, acceptance and adoption are much more likely throughout an organization.
Radiology practices need to reassess their contracts with insurance companies and in turn, their in-house capabilities regarding the management of these relationships. Recent mergers and acquisitions of companies such as Aetna/Humana and Anthem/Cigna are increasingly consolidating power and reducing the ability of smaller practices to negotiate. These large payors typically have teams dedicated to contract negotiations. As a result, it may be of value for smaller practices to hire someone to focus on contracts and these relationships. Organizations must also assess patient registration, pre-authorization, billing, coding, denials and other parts of the revenue cycle to identify areas for optimization as your transition to an accountable care environment.
MACRA is promoting value over volume. The goal is to improve patient outcomes by increasing efficiency, minimizing errors by utilizing guidelines and clinical pathways and using quality metrics to measure guideline adherence and patient outcomes. As hospitals and doctors will be monitored and reimbursed on outcomes, they will, in turn, expect more from the radiology group. Radiology will have to prove its value to the patient care delivery system.
Ensuring that you have the right technology and data in place is vital for your future success professionally and financially. In preparation, workflows need to be assessed and modified accordingly to accommodate new MACRA rules for data reporting. It will be important to establish key performance metrics to ensure efficiency and quality of service.
The Physician Quality Reporting System (PQRS) was established by CMS to shift reimbursement from a fee-for-service structure to a pay-for-performance one CMS approved clinical pathways and quality metrics. MACRA will continue to incentivize service quality through its 2 payment models – a Merit-Based Incentive Payment System (MIPS) or Alternative Payment Model (APM).
McKesson Medical Imaging Consulting™ can help organization standardize quality measures, design and implement analytics and other monitoring tools to track high cost patients and standardize cost measures making it more likely that clinicians accept risk based compensation.
Making MACRA Work
Physicians, unsurprisingly, prefer the status quo so introducing value-based payment models without additional incentives will be a challenge. To help ease transition to MACRA, organizations need to prepare for change in advance of policy implementation so that change is incremental. McKesson is well positioned to help transition radiologists, reading centers and hospitals to the new business model – one in which you will be required to drive and evidence value in order to be compensated. We can help assess readiness and provide comprehensive change management services to ensure MACRA readiness.
Join our workshop on February 8th in Charlotte, NC where we will provide you with the information you need to gain a better understanding of the impact of MACRA on your facility. If you will be at HIMSS ’17 from February 20 – 22, book a demo or meeting in advance to discuss how we can help ease your transition to MACRA, or stop by the McKesson booth 3479.