The impact of the Medicare Access and CHIP Reauthorization Act
(MACRA) of 2015, along with the Centers for Medicare and Medicaid
Services' (CMS) 2016 proposal for its implementation, on radiologists has been explored by a new Harvey L. Neiman Health Policy Institute series of reports.
The work, conducted by a team of radiologists and health services
researchers, is published online in the Journal of the American College of Radiology (JACR).
Under MACRA, most radiologists will initially be paid through the
Merit-Based Incentive Payment System (MIPS), which applies positive or
negative adjustments to fee-for-service payments.
‘The impact of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 on radiologists has been explored by a new Harvey L. Neiman Health Policy Institute series of reports.’
In April 2016, CMS
published an initial proposed rule for MACRA, renaming it the Quality
Payment Program (QPP) that will ultimately link a very large fraction of
physicians' Medicare payments to the quality and value of care. Payment
adjustments under MACRA will begin in 2019, although they will reflect
performance during 2017.
The first part
of the JACR series provides an overview of CMS' proposal for
implementing MACRA legislation via the new QPP, paying specific
attention to the implications and imperatives for radiologists under
"Given that the initial MIPS performance period begins in 2017,
radiologists must begin preparing for QPP and taking actions to ensure
their future success under this new quality-based payment system," said
Andrew Rosenkrantz, the lead study author and a Neiman
Institute affiliate research fellow.
In the second part
of the series, the researchers found that CMS' proposed criteria for
special considerations in new payment models would result in many
radiologists being evaluated using measures not reflective of their
"MIPS will provide special considerations for physicians with a
limited degree of face-to-face patient interaction," said Bibb Allen
Jr., chair of the Neiman Institute advisory board and past
chair of the American College of Radiology Board of Chancellors.
"However, using CMS's proposed criteria for which physicians will
receive special considerations, many radiologists will be deemed
ineligible for these special considerations and thus be evaluated based
on performance categories beyond their control."
"Alternative criteria could help ensure that radiologists are
provided a fair opportunity for success in performance review under
MIPS," added Rosenkrantz.
The ACR applied concepts developed in these articles to inform CMS
that determination of special considerations based on face-to-face
patient interaction for payment policy purposes may best be defined in
terms of the number of Evaluation & Management services performed,
while the number of minor procedures performed is not as useful in that
determination. On Oct. 14, 2016, CMS released its final rule for MACRA
implementation. This final rule modified the criteria for special
considerations under MIPS, consistent with earlier ACR feedback.
defined, at minimum, nearly 90% of diagnostic radiologists and 40% of interventional radiologists will be eligible for the special
considerations and these numbers could increase to 99% and 87% if CMS determines that procedural services will not be included
in its determination of patient facing status. The protections provided
to radiologists by the latest modifications from CMS are supported by
the data demonstrated in the second part of the series.
Rosenkrantz, Allen and their colleagues noted that continued
investigation is warranted to optimally determine the extent of
radiologists' face-to-face patient interactions.