Data from an EHR for ACI and quality category analysis. Photo via SA Ignite
Eligible clinicians across the country are in the midst of their first performance year under MACRA. Metrics reported this year will tell the tale in 2019 as far as what kind of reimbursements, bonuses, or more forebodingly, penalties they will see.
Unfortunately, a number of studies show clinicians aren't ready for MACRA. While some are simply struggling to make upgrades and changes that will facilitate compliance, many are not sufficiently familiar with the ins and outs of the law and how it will impact them.
However there are tools, and some accompanying best practices, that can help providers get started down the right path.
"CMS has special status information up on the QPP website right now through what they are calling a lookup tool," said Jennifer McLaughlin, senior associate director of government affairs for the Medical Group Management Association. "But, from what we've seen when our members go in and plug in their Medicare identifier, if they do get a notice that they do have a special status saying that they are considered a small practice in 2017, there's not been clear information for them about what that means or how that impacts their MIPS score or what their requirements are."
One issue McLaughlin stressed is the need for CMS to make information on the Quality Payment Program more organized and accessible, instead of having busy providers go to their website and sift through numerous informational PDFs.
MGMA has an online forum to help providers inform themselves and share their experiences so that they all can learn from each other's journeys with MACRA.
That kind of sharing is crucial for those still trying to find their way, perhaps sidestepping a few "potholes" thanks to the experience of those who've already been there or are better prepared.
"When groups are looking at different options and different measures that may apply. In 2017 they can only pick one measure for quality, so they want to make sure need to pick one that allows them to reflect the quality initiatives that they are actually efforting at that time," McLaughlin said.
She also said to make sure you have a thorough understanding of what your practice's eligibility is, and that you are getting the most out of the measures you choose to report.
"Look at return on investment in your participation. Can you leverage any of the activities that you may be doing in MIPS outside of just the reporting program?"
Eligible clinicians can find a useful springboard in the American Medical Association's Payment Model Evaluator tool, which can be used to assess readiness to participate in MACRA as well as which path within the QPP is best, MIPS or APM.
Then, they can move on to assessing the gaps in what they are doing now in their practice and what they need to do participate. Many physicians who were not participating in PQRS and meaningful use will have bigger gaps than those who did participate.
"It will depend on the capabilities of the EHR in terms of gathering data in a form that can then be reported so assessing that gap is key and that's part of what our tools do," said AMA President David Barbe.
Once done with the Payment Model Evaluator, clinicians can move on and seek deeper educational materials with the Steps Forward practice transformation series, a series of modules that physicians can pick and choose from according to which ones are most relevant to them. Some help physicians understand what the options are for reporting on quality for their practice, and outline issues physicians want to consider.
"Some modules help them understand how to use their EHR to help them report for MACRA, both gathering and reporting the data so it's less labor intensive," Barbe said. "The modules are somewhat interactive but mostly informational. You work through it and it helps you see what direction you need to go."
SA Ignite got their start in the meaningful use program. The company watched as the legislation changed and got reissued after feedback. Beth Houck, their vice president of client services, said they recognized early that the simplification of the management of the MU program was a big need in the market. They created Meaningful Use Assistant, a tool they call an "end-to-end" solution that helps users navigate all aspects of the program, from administrative aspects to interpreting regulatory aspects correctly.
"Our company was built on that foundation of simplification and deep regulatory knowledge to ensure you're taking the program from soup to nuts and getting all the pieces of it done correctly," she said.
Houck said they did the same thing for PQRS. Then QPP came out, so their MACRA tool is a natural extension of their products.
The tool is a web-based platform licensed on per clinician basis. Typically the person buying it is the person responsible for managing their QPP participation.
First, there is data that needs to be collected to start analysis and assist the client in evaluating their starting point. SA Ignite needs their list of physicians and associated pins and data that their EHR is producing for the ACI and quality categories. They carry a light connection to the EHR to get that data and client provides a physician list, Houck said.
All of that is loaded into a database, then they "ping" CMS, who uses their lookup tool to determine each clinician's eligibility. This enables the software to show them what the score would be for each clinician, and accordingly, what the Medicare Part B expected incentive would be at the individual level. The tool can also compare that to the total PIN submission.
"All that info starts to underlie all of the characteristics that need to be in place so we know what regulations to layer on top of that provider's profile or that pin's profile," Houck said.
The individual scores versus what you'd get for a group is also automatically calculated. Moreover, the tool allows the process to switch from calculating actual performance scores to
examining analytics and enabling the client to do more performance monitoring as they go along.
"The software can send score cards out to a designated person, which can inspire behavior change," Houck said.
The program comes with support services, including overall guidance and quarterly check-ins to make sure customers are using the software and performing processes correctly. The quarterly check-ins are when they layer in some higher order analytics that can help tell customers how they might have disproportionate impact on their score overall.
However, before getting started with any MACRA tool, Houck listed some best practices. First is form before function. Houck said organizations need to recognize that you can't just buy a tool and have everything start to work just because of the tool. You need to get a foundational organizational structure in place first. Then the tool can help enable information transfer between all those different areas and provide a foundation.
"So when you're in your MACRA steering committee meeting everybody knows you're looking at the same information from the same place at the same time."
She also said often the data will expose organizational dysfunction.
"If the old PQRS is run by one person and the MU manager is someone else and they've never met, you should start there."