The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) has arrived. The program was passed by Congress, with CMS backing, with the intention of streamlining existing quality programs such as Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value Based Modifier (VBM). This “shift” is intended to assist in transitioning from volume based reimbursements to quality based reimbursements.
MACRA ceases the traditional end of year Congressional impasse of determining reimbursement rates for the upcoming year. Non-FQHC entities will receive modest increases of 0.5% or less through 2019. Incentive increases based on quality and cost will rise (or fall) based on practice scoring as the program matures.
The impact of MACRA on FQHCs lies in the rule’s present status and future legislation by regulators.
The key with MACRA for FQHCs is the word “Medicare.” MACRA is a Medicare based program in present regulatory format. CMS and Congress have not presently defined how to integrate FQHC entities into the program. While there are conversations at the federal level on how to assimilate existing quality programs with MACRA initiatives, these decisions are yet to be made or defined.
The main quality reporting program for FQHCs will remain MU. FQHC’s generally participate in these programs through Medicaid at the state level. This model will continue as will attestation requirements by provider.
The present MACRA model repeals the sustainable growth rate (SGR) and increases incentive opportunities based on outcome data. As FQHCs utilize a prospective payment system (PPS), the incentive opportunities and payment schedules would need to be reconciled by Congress before implementation.
Last, there are discussions of moving MACRA guidance to private or commercial insurance payors. This change would require an alteration in contracting terms with these payors. Additionally, FQHCs would need to examine and change their cost, revenue, and quality forecasting for these payors should this change take effect.
As the future for MACRA and FQHCs are yet to be determined, we recommend entities focus on three areas to be up-to-date of potential changes:
1. Centers should maintain ongoing communications with federal and state legislators as well as their state primary care association and the National Association of Community Health Centers. http://www.nachc.org/.
2. Stay current on MU requirements and attestation requirements for your state.
In addition to maximizing financial opportunities from the program, some requirements of MU would likely roll into MACRA requirements. Comfort with the program and requirements will easy any required transition to MACRA.
3. Monitor your electronic information and data integrity. Information from your EMR will be part of your base for reporting under MACRA. Data integrity with completed fields and demographics will assist in a transition as above. As with present UDS requirements, completeness and accuracy of the source data is a key component to the reporting process.
So – MACRA for me? Maybe – stay tuned!
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