The American College of Radiology (ACR) expressed general satisfaction with the flexible aspects of the MACRA final rule in comments submitted Dec.16 to the Centers for Medicare & Medicaid Services (CMS).
Effective Jan. 1, 2017, the MACRA final rule lays out how physicians can start participating in CMS’ new Quality Payment Program by either reporting measures under the Merit-Based Incentive Payment System (MIPS) or advanced alternative payment models (APMs).
The rule discussed criteria for the Physician-Focused Payment Model Technical Advisory Committee. It is an independent body that has begun accepting applications from stakeholders to develop new APMs to be recommended to and hopefully adopted by CMS.
The ACR is generally pleased with the final rule because it offers considerable flexibility for physicians to participate under MACRA’s “Pick Your Pace” program and also loosens requirements for physicians who come up short with measures to report in the MIPS categories. The final rule also allows for flexibility for physicians to either participate in APMs or if they fall short in the requirements to then elect to report measures under MIPS to avoid a penalty.
Small and rural practices are allowed to report MIPS at a lower level while they work to transform under the guidance of CMS through the Transforming Clinical Practice Initiative.
The ACR and other specialty physician organizations will be unable to fully comment on or analyze the effect of the rule until Medicare releases its patient-facing code list for the regulations. The composition of this list will clarify how much of radiology is considered patient facing versus non-patient facing, a determination that will affect the type and amount of information that needs to be reported under MIPS. This list is due to be released by the end of 2016. The ACR will be sure to notify the membership once it is released.