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©2015 American Academy of Neurology

©2015 American Academy of Neurology

MACRA and the Axon Registry: What

You Need to Know

Lyell K. Jones Jr. MD, FAAN

Vice Chair, AAN Registry Committee

Associate Professor of Neurology, Mayo Clinic

September 8, 2016

©2015 American Academy of Neurology

Goals• By the end of this session, we want you to be able

to explain to a colleague:

The essential aspects of MACRA and its effect on CMS

payment systems

Differences between the two major components of

MACRA: the Merit-Based Incentive Payment System

(MIPS) and Alternative Payment Models (APM)

Interactions between the MACRA and the Axon Registry

Slide 2

©2015 American Academy of Neurology

Background: Health Care Costs

Slide 3Source: Kaiser Family Foundation

Projections of National Health Care Expenditures and Share of GDP, 2013-2023

©2015 American Academy of Neurology

Background: Health Care Costs

Slide 4CMS, 2015: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-01-26-3.html Accessed 2/5/15

©2015 American Academy of Neurology

Background: Current CMS Programs

• Physician Quality Reporting System (PQRS)

Providers who report approved quality measures avoid

penalties (up to -2% in 2017)

CMS will be moving to performance based adjustment

• Value-Based Payment Modifier (VBPM)

Providers are scored on PQRS performance and resource use

(cost) to receive bonuses or penalties (-4% to +4%)

• Meaningful Use (MU), or EHR Incentive Payment Program

Has transitioned from bonuses for attestation to penalties for

failing to attest (-4% in 2017)

Slide 5

©2015 American Academy of Neurology

What is MACRA?•The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

•Passed with wide bipartisan and bicameral support

House vote: 392-37

Senate vote: 92-8

• Signed into law April 16, 2015

•Proposed rule released April 2016

Slide 6

©2015 American Academy of Neurology

Medicare Payment Modernization• Permanent repeal of the SGR

• MACRA implements a completely new payment

structure

• Rulemaking will be critical to implementation

Slide 7

Volume Value

©2015 American Academy of Neurology

Quality Payment Program

Slide 8

©2015 American Academy of Neurology

MIPS Exclusions

First year of Medicare Part B

Participation

Below low volume threshold for

patients seen/ Medicare

allowable charges

Qualifying participant in an

approved advanced

Alternative Payment Model

(APM)

Slide 9

©2015 American Academy of Neurology

MIPS Performance Categories• Quality

• Resource Use

• Advancing Care Information

• Clinical Practice Improvement Activities

Slide 10

©2015 American Academy of Neurology

MIPS Performance Categories

Quality (50%)

Resource Use (10%)

Advancing Care Information(25%)

Clinical Practice ImprovementActivities (15%)

Slide 11

©2015 American Academy of Neurology

MIPS Performance Categories• Quality (50%)

Will closely resemble PQRS

Measures will be selected from multiple domains:

–Clinical care

–Safety

–Care coordination

–Patient and caregiver experience

–Population health and prevention

Slide 12

©2015 American Academy of Neurology

MIPS Performance Categories• Quality (50%)

Certain measure types will be given priority for

inclusion:

–Outcomes

–Patient experience (such as patient reported

outcomes or PROs)

–Care coordination

–Appropriate resource use

Slide 13

©2015 American Academy of Neurology

MIPS Performance Categories• Resource Use (10%)

This will be similar to the Value-based Payment Modifier

(VBPM)

New “classification codes” will be used:

–Care episode groups: likely will be used to identify

episodes in episode-based payment models

–Patient condition groups: likely will be used for group

assignments with condition-based payment

–Patient relationship categories: likely will be used to

define provider attribution of patient outcomes

Slide 14

©2015 American Academy of Neurology

MIPS Performance Categories• Advancing Care Information (ACI, formerly

Meaningful Use or MU) (25%)

Will generally align with existing MU requirements

Inconsistencies between current programs (e.g., PQRS

and MU) will be eliminated

Approved measures (in the Quality category) will

automatically satisfy the MU quality measure reporting

requirements

Slide 15

©2015 American Academy of Neurology

MIPS Performance Categories• Clinical Practice Improvement Activities (CPIAs) (15%)

This is new for CMS, but will feel similar to practice improvement activities in other parts of our practice

Approved CPIAs will likely include:

–Expanded practice access

–Population health management

–Care coordination

–Beneficiary engagement

–Patient safety and practice assessment

–Participation in an APM

QCDR (registry) participation will positively impact score

Slide 16

©2015 American Academy of Neurology

MIPS Risk Corridor

-15.00%

-10.00%

-5.00%

0.00%

5.00%

10.00%

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Annual Update Max. Penalty Bonus Potential

Slide 17

Combined PQRS, MU,

VBPM penalties

©2015 American Academy of Neurology

Alternative Payment Models• Providers that receive significant revenue from

qualifying APMs are exempt from MIPS

• Eligible for 5% bonus 2019-2024

• Qualifying APMs:

Use certified EMR technology

Employ quality measures similar to MIPS

Must be risk-bearing

• Model criteria to be further defined by CMS

Slide 18

©2015 American Academy of Neurology

Alternative Payment Models• Current examples of APMs:

Accountable care organizations (ACOs)

Patient-centered medical homes (PCMHs)

“Bundled” payments/episode-based payments

• Advanced APMs described in proposed rule are very

narrowly defined

Flexibility and specialty-relevant models will be

important to encourage neurologist participation

The AAN is actively developing neurology-relevant APMs

Slide 19

©2015 American Academy of Neurology

Alternative Payment Models• A Technical Advisory Committee (PTAC) has been

formed to advise CMS on development of new APMs

11 members, 7 physicians

• New APMs may be submitted on an ongoing basis

• CMS is tasked with developing APMs targeted to:

Specialty practices

Smaller practices

Risk-based models

Slide 20

©2015 American Academy of Neurology

Overall Payment Updates2015-2018 2019 2020 2021 2022-

2024

2025 2026+

Conversion

Factor

Update

0.5% 0.5% 0% 0% 0% 0% MIPS: 0.25%

APM: 0.75%

MIPS

Adjustment

Factor

PQRS, MU,

and VBPM

penalties in

effect (-

4.5% to -

10%+)

-4% to

+4%*

-5% to

+5%*

-7% to

+7%*

-9% to

+9%*

-9% to

+9%

-9% to

+9%

APM Bonus 5% 5% 5% 5%

% Medicare

Revenue

from APM

25% 25% 50% 50-75% 75% 75%

Slide 21*additional bonus for top performers NOT

included

©2015 American Academy of Neurology

MACRA: Specialities and Subspecialties

•While the proposed rule reduced the number of

reported quality measures from 9 to 6, there may

be few relevant options in a subspecialty practice

• Advanced APMs are narrowly defined, with

unresolved barriers for specialty practices

• Risk adjustment in the proposed rule does not take

into account subspecialty patient populations

©2015 American Academy of Neurology

How is AAN preparing for MACRA?• The AAN has been very active in the regulatory

advocacy phase, urging CMS to consider neurologists and their patients in the rulemaking process

• AAN staff and volunteers are actively working to develop new payment models that better serve neurologists

• Using numerous channels (trained speakers, AAN.com, online videos, the Annual Meeting, etc), the AAN is working to educate neurologists on the urgency of approaching payment changes

©2015 American Academy of Neurology

Axon RegistryTM Participation •Will seamlessly report Quality data and ACI

attestation in MIPS

•Will positively impact score on CPIA component of

MIPS

•Will give practices access practice trend data and

identify potential areas for improvement

• Go to www.aan.com/practice/axon-registry for

more information

Slide 24

©2015 American Academy of Neurology

MACRA and the Axon Registry• The rule proposes QCDRs act as intermediaries on

behalf of clinicians and submit data for the Quality,

CPIA, and ACI categories:

Quality - Means for quality reporting component

Clinical practice improvement activities – Component of

several CPIAs and as a means to attest to participation

Advancing care Information- Means for attestation in

ACI component

• In the future, align MIPS/Axon measures and

further clarify CPIAs

©2015 American Academy of Neurology

MACRA and the Axon Registry• Concerns with the proposed rule:

Little detail in proposed rule on requirements for QCDRs

No guidance for vendors or QCDRs

As CMS further clarifies, AAN will assess AAN’s potential

financial impact of providing service and vendor

capability to develop the technology

©2015 American Academy of Neurology

What do you need to do now?• If you haven’t reported on meaningful use (MU),

start now

• If you haven’t reported PQRS measures, start now

• If you have done PQRS, become familiar with your

QRUR reports to identify areas for improvement

©2015 American Academy of Neurology

MACRA: Take Away Points• MACRA signals the transition to value-based payment

systems

• Many details have yet to be clarified in the final

MACRA rulemaking

• The ideal MACRA participation pathway for any one

practice will depend on a number of factors

• Axon will be an important tool for neurologists in

the MACRA era

Slide 28

©2015 American Academy of Neurology

Questions?

©2015 American Academy of Neurology

Thank you!