September 15, 2017

ACR Explores Potential MACRA Legislative Changes

In collaboration with the American Medical Association (AMA) and other national medical specialty societies, the American College of Radiology (ACR®) is exploring the possibility of developing potential federal legislation to alter select portions of the Medicare Access and CHIP Reauthorization Act (MACRA).

Enacted in 2015, MACRA replaced the flawed Sustainable Growth Rate (SGR) formula for determining Medicare physician reimbursement and granted providers increased budgetary certainty by authorizing five years of stable payments through 2019. In addition, the legislation accelerated the movement away from paying for the volume of services to the value of care by offering greater financial incentives for physicians to enter into risk-based Alternative Payment Models (APMs), including Accountable Care Organizations (ACOs), as well as streamlining multiple existing quality measurement programs into a modified fee-for-service program known as the Merit-based Incentive Payment System (MIPS).

While no formal bill has been introduced at this time, the potential MACRA reform legislation is likely to focus on granting the secretary of Health and Human Services (HHS) greater flexibility regarding the percentage weights assigned to the various MIPS performance categories, specifically Quality, Cost, Improvement Activities, and Advancing Care Information (formerly the Electronic Health Record Incentive “Meaningful Use” Program), along with the method used to calculate the MIPS performance threshold.

Effective in 2017 and 2018, the MACRA statute stipulates that the percentage weights to the performance categories used to calculate an individual physician’s composite score are as follows:

  • Quality - 60 percent
  • Cost - no more than 10 percent in 2017 and no more than 15 percent in 2018
  • Improvement Activities - 15 percent
  • Advancing Care Information - no more than 25 percent 

A physician’s composite score, in turn, is compared to the overarching MIPS performance threshold, which is the mean or median of the composite scores for all MIPS-eligible professionals in a given performance year.

Physicians with individual composite scores above the performance threshold for all MIPS participants receive a positive increase in Medicare reimbursement, while those providers who fall below the benchmark receive payment reductions. The MIPS performance threshold is reset every year so while a radiologist’s individual composite score in one year doesn’t affect their composite score in the following year, the legislation allows for credit for improvement over multiple years.

The ACR, AMA, and other national medical specialties are most concerned with the Cost category. Effective in 2019, the MACRA statute requires this performance category to increase to 30 percent of a physician’s total composite score. The medical community is concerned about the lack of experience with new episode-based cost measures and believes CMS needs additional time to develop, test and refine these new measures prior to including them in the MIPS program for accountability using a substantial category weight.

In addition, 2019 marks the year by which the HHS secretary is required to use the mean or median when calculating the MIPS performance threshold. As a result, the forthcoming legislation will seek to allow the secretary to allow Cost to count for no more than 10percent of an individual physician’s composite score between 2019 and 2023. This potential MACRA bill will also attempt to allow the secretary to not be required to use the mean or median when calculating the MIPS performance threshold during that five-year span, as well.

ACR’s Government Relations office is closely monitor this legislative effort and future editions of the Advocacy in Action Enews will continue to provide the most up-to-date information pertaining to MACRA.