With the final rule on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) released by CMS in October 2016 and the rule going into effect in CY 2017, healthcare providers are now tasked with the readiness and implementation plan to meet the parameters of the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs). The Department of Health and Human Services (HHS), in collaboration with partners in the private, public, and non-profit sectors, launched the Healthcare Learning and Action Network (LAN), to assist in advancing the adoption of value-based healthcare and alternative payment models. As part of this effort, the LAN developed an APM framework that categorizes the transition from fee-for-service to population-based quality care. The framework is categorized by 4 different payment models (see footnote):
- Category 1: Fee for service – no link to quality & value
- Category 2: Fee for service – link to quality & value
- Category 3: APMs built on Fee-for-Service architecture
- Category 4: Population-Based Payment
The general summary of the technology implications are based on a health IT framework developed for ONC (see footnote). Current health IT infrastructure for most providers already support Category 1 and 2 with capabilities such as an organizational EHR, elements of care coordination, pay for reporting, data aggregation/sharing and integrated workflows. Given the complexity of MACRA and the vast IT requirements to transition towards the full APM model, this document will only highlight some key points around Category 3 and 4 as they offer the highest risk but also the most reward. Providers planning for MACRA should first conduct an objective assessment of their readiness along with careful evaluation of options to pursue the path chosen. From an infrastructure perspective, providers may consider using multiple systems for these functions or rely more on their vendor partners to build out the platforms that incorporate these capabilities into their current environment.
This summary was not meant to minimize the vastness of the MACRA rule and the efforts required to achieve it but rather an attempt to provide some clarity on how organizations should allocate resources for a formal evaluation of their readiness and options to meet requirements at different category levels.
Health Care Payment Learning & Action Network (hcp-lan.org) under work products, APM framework