Tag Archives: MACRA

Exploring the nuances of MACRA

The major terms and conditions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) are becoming more well-known during the first performance year, but some aspects of the new physician payment system law still can be elusive for physician practices and other healthcare organizations. In this article, Milliman’s Pamela Pelizzari discusses details that may be overlooked regarding participation in the Merit-based Incentive Payment System track and the advanced alternative payment model track of MACRA.

This article was published by the Healthcare Financial Management Association.

MACRA considerations for Medicare Advantage plans

The Medicare Access and CHIP Reauthorization Act (MACRA) makes significant changes to the Medicare payment system by introducing a quality-based payment model. While MACRA primarily affects Part B clinicians, there are numerous implications that Medicare Advantage (MA) plans should consider. A strategic approach can help MA plans understand and respond to the legislation.

In the article “MACRA and Medicare Advantage plans: Synergies and potential opportunities,” Milliman actuaries explore the answers to the following questions:

• How will MACRA affect MA plans’ provider payments?
• What synergies exist between MACRA’s quality scoring and the MA Stars quality program?
• How can MA plans help providers achieve Qualifying Participant (QP) status?
• What incentives exist under MACRA for providers to improve risk score coding?
• How are MA plans in the market responding to MACRA?

Read Milliman’s “MACRA: The series” to learn how the legislation will affect providers, alternative payment models, and health plans

How will MACRA affect the Medicare Supplement market?

Clark_L_KennethWhat does recently passed legislation referred to as MACRA (Medicare Access and CHIP Reauthorization Act of 2015 ) mean for the Medicare Supplement industry? While the impact on Medicare Supplement doesn’t occur until 2020, individual carriers are in a position now to plan a course to proactively mitigate risks or exploit opportunities.

The Medicare Supplement market will split into two distinct markets
There will be those that are newly eligible for Medicare in 2020 and later (NE group) who don’t have access to Plans C/F and the non-newly eligible (NNE group) that will still have access to Plans C/F. Why is this important? While the NNE group will shrink over time, it will still comprise a significant segment of the market in the early 2020s.

Overall loss ratio experience should be better for a few years following MACRA implementation
How is this possible? Consider that for new business sold in the early 2020s, the NNE group that purchases Plans C/F will no longer consist of 65-year-olds who qualify for open enrollment without medical underwriting. Plan C/F morbidity will improve while Plan D/G morbidity will increase. For as long as Plans C/F make up a significant volume (and keep in mind this is older individuals at the higher rate levels), the overall loss ratio levels should be lower, all else being equal.

In spite of more favorable experience, however, retention dollars are expected to be lower for all years following MACRA implementation
While overall loss ratio experience may improve, the amount of retention dollars (premium less claims) will be lower, given an increased exposure to lower benefit Plan D/G coverage that doesn’t include the Part B deductible. The overall impact through 2025 is likely to be in the billions of dollars.

To learn more about how MACRA will impact the Medicare Supplement market, read my article “Will the Medicare Supplement market have “2020” vision in the world of MACRA?

Qualifying APM participant considerations

This paper by Milliman’s Charlie Mills, Pamela Pelizzari, and Christopher Kunkel explores the challenges and opportunities regarding participation in an Advanced Alternative Payment Model (APM) track under the Medicare Access and CHIP Reauthorization Act (MACRA). The authors also discuss why becoming Qualifying APM Participants (QPs) may be desirable to some providers as well as the risks they might encounter through the process.

Here is an excerpt from the article:

Opportunities associated with QP status

Financial opportunities

Despite the potential downsides to participating in Advanced APMs and seeing QP status, there are also potential financial benefits, including the following:

A lump-sum payment equal to 5% of their prior year’s payments for Part B covered professional services. QPs can become eligible for this lump-sum incentive payment for years 2019 through 2024. Overall, this is the primary financial opportunity for QPs.

Insulation from the potential downside of the MIPS adjustment. In general, MIPS is a budget-neutral (i.e., zero-sum) program, with a financial downside of 4% in 2019, growing to 9% in 2022. Because QPs and Partial QPs are excluded from MIPS, they are not exposed to MIPS’s downside and do not have to navigate the hundreds of quality and performance measures that make up MIPS.

Opportunities for shared savings from the Advanced APM. QPs will have the opportunity to share in gains (and will generally be required to share in losses) from the Advanced APMs they participate in.

Higher conversion factor increases starting in 2026. Starting in payment year 2026, QPs will receive a conversion factor increase of 0.75% compared with 0.25% for non-QPs. Over time, this could result in significantly higher payment rates for QPs versus non-QPs.

Clinical integration benefits

Several of the currently available Advanced APMs aim to align incentives across different types of providers. For example, ACOs encourage physicians and hospitals to work together to ensure beneficiaries receive appropriate care that can keep them healthy and out of hospitals. In many cases, however, individual physicians do not see the financial benefits of these programs without entering into what can be complex and time-consuming gainsharing arrangements. By providing a 5% lump-sum incentive payment to QPs, MACRA serves to create an even greater incentive for physicians to participate actively in Advanced APMs.

While other payer Advanced APMs do not contribute to QP threshold calculations until performance year 2019 (incentive payment year 2021), it’s possible that the increased engagement physicians have in Advanced APMs that is due to MACRA will have trickle-down effects on other lines of business and patient populations beyond Medicare fee-for-service. This could serve to improve the quality of care and reduce costs for patients covered by other payers.

Overview of the Merit-Based Incentive Payment System

As part of the Medicare Access and CHIP Reauthorization Act (MACRA), the Merit-Based Incentive Payment System (MIPS) seeks to tie Medicare payments to provider performance within the fee-for-service (FFS) system.

In her article “MIPS adjustment overview,” Milliman’s Pamela Pelizzari discusses the MIPS inclusion criteria and the MIPS Composite Performance Score (CPS). She also demonstrates how the CPS leads to the determination of the MIPS adjustment factor and explores the effect of changing practices on both the CPS and MIPS adjustment factor.

The article is part of a series examining the impacts of MACRA on providers, alternative payment models, and health plans. To read other articles in the series, click here.

Advanced APM considerations for clinicians

Two value-based reimbursement models exist under the Medicare Access and CHIP Reauthorization Act (MACRA) that tie Part B payments to clinician performance: the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (Advanced APM) track. The Advanced APM track encourages groups of clinicians to shift from fee-for-service to delivery models in which clinicians assume more accountability and risk for the cost and quality of care. In the initial years of the program, MACRA provides incentive payments to early APM adopters.

This paper written by Milliman’s Lynn Dong and Pamela Pelizzari explores the definition of an Advanced APM, how providers can qualify to be paid under the provisions of the Advanced APM track instead of under MIPS, and why that might be desirable. In addition, the authors highlight the need for careful evaluation regarding APM participation because there is often a complex interaction between the risk inherent in an Advanced APM and the benefits under MACRA.

The article is part of a series examining the impacts of MACRA on providers, alternative payment models, and health plans. To read other articles in the series, click here.