Prior to 2022, CMS has never penalized more than 3% of all providers. But the laws change this year. CMS is required to penalize everyone with below-average scores. This means that somewhere near 50% of all providers will pay into the penalty pool.
Why is this important? Penalties fund positive payments!
Average Scores get tougher to achieve in 2022. The first five years of MACRA were structured to be easy. But some of those structures go away this year. Bonus points on Quality go away, benchmarks get tougher, and regulations overall become less relaxed.
You may recall that MACRA has two funding sources. First is a "revenue neutral pool", filled up by penalties. This pool allows top performers to earn up to 9% MACRA positive fee adjustments - but only when around half of all providers earn penalties.
And this is exactly the way the MACRA program will behave in 2022 and beyond. Under Law, the "penalty threshold" will be set by CMS at a rate based on average scores. Everyone under average gets penalized, and everyone above average gets rewarded. (Prior to 2022, CMS was allowed to gradually "ramp up" to this level with penalty thresholds much lower than average).
So from 2022 and on, providers can actually start to earn 9% of Medicare payments on MACRA.
But there is a second pool of money, that expires after 2022. Congress initially funded a fixed fund of $500 million annually for "exceptional performance". Providers scoring above a pre-set exceptional performance threshold could earn from 0.5 to 10.0 percent on top of the revenue neutral funds. Here again, up until 2022, the exceptional performance threshold was artificially set so low ... that almost everyone was exceptional! The $500 million had to be spread across a much larger population of physicians than was initially intended. In 2022 that threshold is set by formula to be 25% higher than the revenue neutral average. For the first time, exceptional performance funds will be allocated to a much smaller pool of providers - and qualifiers will finally earn their full share.
But 2022 is the final year for exceptional performance. It is truly our "last best year" for MACRA money.
Here is a fun offer. Bring me the name of a TIN who might benefit from your MACRA Program. Watch while our tools identify all the physicians, query CMS for Medicare payment history, and project their MACRA reimbursement - based on what score you tell us to target.