MACRA: Alignment Beyond The New Advanced Alternative Payment Models

The Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”) provides for two reporting tracks for eligible practitioners:  the Merit-based Incentive Payment System (“MIPS”) and Advanced Alternative Payments Models (“AAPMs”). There are only a few models that have been approved by the Centers for Medicare and Medicaid Services as AAPMs for 2017, and the list of expected 2018 AAPM models is quite short.  Further, the AAPM requirements include, among other criteria, a strict risk-bearing standard.

Missing from the list of AAPMs: clinically integrated networks (“CINs”), physician-hospital organizations (“PHOs”) and many of their brethren.  However, that does not mean that CINs and PHOs and other non-advanced alternative payment models (“APMs”) are about to fade into the night.  On the contrary, it is likely that these types of models will continue to proliferate.  The reporting requirements for eligible practitioners on the MIPS track are quite daunting.  Additionally, independent practitioners will need to expend significant sums and time reporting for MIPS.

This is where the non-advanced APMs come in. By this time, most of the remaining independent practitioners fall into one of three categories: (1) those who do not want to be employed by a health system; (2) those who a health system does not want to employ and (3) those that were employed by a health system, but are not any longer.  Yet, most of those practitioners will be subject to MACRA and will have a difficult time going it alone.  Moreover, in an era of continued consolidation and competition, health systems continue to evaluate alignment models with community practitioners.

It is possible that independent practitioners will now see more than ever the value of joining a non-advanced APM. The non-advanced APM likely has the personnel and the resources to help practitioners choose the appropriate measures for MIPS reporting, compile the necessary data, analyze the data and complete the actual reporting.  Further, the cost of joining and maintaining participation in a non-advanced APM for an independent practitioner is likely much less than what it would cost that same practitioner to comply with MACRA on his or her own.  Additionally, these benefits would be in addition to those already offered by non-advanced APMs such as data sharing, best practice protocols and joint contracting.  Non-advanced APMs allow the practitioners to remain independent, but also bring alignment, on a non-exclusive basis, with a health system.

MACRA represents a significant change for health care providers, but it also represents a great opportunity.