NAACOS Alert on Release of MACRA Final Rule

On October 14, the Centers for Medicare & Medicaid Services (CMS) released its highly anticipated final rule implementing 2017 reporting for the Medicare Access and CHIP Reauthorization Act (MACRA), which corresponds to 2019 Medicare physician payment adjustments. The rule is available here and CMS also released this Executive Summary of the rule.

The final rule includes critical details on MACRA alternative payment models (APMs), including those that CMS considers Advanced APMs, which qualify for 5 percent annual bonuses from 2019 through 2024. For 2017 performance, APMs included as Advanced are detailed in this resource. That list includes Medicare Shared Savings Program (MSSP) Track 2 and 3 ACOs and Next Generation ACOs, but not MSSP Track 1. We are disappointed that CMS finalized its proposal to not include Track 1 MSSP ACOs as Advanced APMs.

However, following strong advocacy from NAACOS to create a new lesser-risk track for ACOs, CMS will be introducing a new MSSP Track 1 Plus (1+) with lower levels of risk than what is currently required for Medicare ACOs in two-sided models. We are also pleased that ACOs that participate in the Merit-Based Incentive Payment System (MIPS) will receive favorable benefits based on their ACO participation. MIPS is the default program for Medicare physicians and reporting starts in 2017 for those not in Advanced APMs or for individual Advanced APMs, such as a Track 3 MSSP ACO, that does not meet the “Qualifying APM Participant” threshold.

To help ACOs understand the critical elements of this lengthy and complex regulation, NAACOS created The ACOs Guide to MACRA. To obtain a copy of this in-depth analysis, please visit this webpage.