2019 is harder for everyone under MACRA
The basic relationship between MACRA / QPP and ACO has not changed as a result of 2019 regulations, but the relationship between ACOs and their clinics bears review. Every provider needs to be on the newest version of their EHR, for "Stage 3" requirements. 2019 is more difficult because of tougher PI Scoring rules, topped out Quality Measures, higher MIPS thresholds, and the requirement for new EHR upgrades to Stage 3 measures.
PI Scores reduced by 50 points across the board
Changes in the PI scoring system means that providers who "maxed out" 2017 and 2018 with PI scores of 100 will only score 50 points. Bringing those providers back up to snuff will require attention throughout 2019.
Because the biggest MACRA impact on ACOs is for Promoting Interoperability (PI), and because PI scores will be cut in half compared to prior years, ACOs will need better tracking tools, more frequent interaction on PI (we like monthly), and an ability to understand MACRA's financial impacts in addition to tracking Shared Savings / Loss risk.
Two-sided Risk Arrangements don't eliminate MACRA
Over the next couple years, all ACOs will glide into two-sided risk arrangements as Advanced APMs, or be forced to unwind their overall operations. Either scenario creates new MACRA challenges. For example, even Advanced APMs are likely to have some providers "fall out" of the ACO as Partial Qualifying Participants (Partial QPs). These Partial QPs are not required to file MIPS content, but in many cases will actually receive more MACRA reimbursement than the standard 5% earned by their Qualifying Provider (QP) colleagues.
MIPS Data goes public for Physician Comparisons
The big hidden topic this year will be the publication of MIPS performance scores on the Medicare Physician Compare site. CMS has done a really incredible job with creating a tool that patients of all types (not just Medicare) can use to select a new provider. For now, this is the only location where patients will use MIPS content (particularly CQM scores), but very soon MIPS scores will be published in a downloadable database. Once that happens, we should expect most physician comparison tools to incorporate the same content. The upshot will be that a provider with a higher "performance" or "quality" score will appear more desirable, and may pick up patient flow from those providers with lower scores.
QPP Eligibillity Inquiry Site
ACOs register their TINs and providers through mechanisms separate from QPP / MACRA reporting, and in some cases, not all providers registered to an ACO end up being eligible as MIPS APM (ACO) participants. The workaround for ACO MACRA is to periodically check the QPP Eligibility Inquiry site to see how CMS sees your providers for MACRA purposes, and treat them accordingly. Remember, this site is only refreshed by CMS for specific snapshot dates (generally August 31 and December 31). The data is generally quite good, although we have found occasional errors, and keep track of site accuracy in a blog entry we update regularly.
Also, since QPP inquiries tend to be one-at-a-time, we have built into MACRA Monitor the ability to conduct those inquiries efficiently, and automatically embed the results into MACRA Monitor so you can treat "exception" providers appropriately.
Improving MACRA Metrics comes from a regular program, throughout the year. We get started as soon as a full month's data is available, and follow a regimen of extract, report, analyze and plan and act for every month thereafter.
C3 Partners, LLC 414-640-2817 28717 Blue Crane Court, Waterford, WI