Making Sense of MACRA

After a slew of feedback from healthcare and HIT professional organizations, like CHIME, AMA and MGMA, CMS announced new flexibilities in the Medicare Access and CHIP Reauthorization Act (MACRA) final rule. Though CMS released the final ruling several weeks ago, physicians still struggle to grasp the impact or even understand what the new reimbursement structure is.

MACRA replaces the old sustainable growth-rate formula for physician pay. Under MACRA, physicians can pick from one of two Medicare reimbursement tracks – the Merit-based Incentive Payment Program (MIPS) or Advanced Alternative Payment Models (APMs). To better aid physicians with these programs, CMS has set up additional resources:

  1. With $700 million in funding, CMS created practice transformation networks as frontline assistance focusing on elevating clinicians’ population health to enable physician success under MIPS and eventually transition them APMs.
  2. With $100 million in funding, CMS specifically directed aid toward solo, small and rural health practices to get them up to speed and in the know about reporting requirements and means for success.

Beyond these initiatives, how can you become better informed? For a breakdown of MACRA regulations and questions to consider, check out our slide set Making Sense of MACRA.


Embracing Proposed MU Revisions

Recently, the CMS and ONC announced a proposed rule that would provide additional flexibility to healthcare organizations and facilitate their continued participation in the Meaningful Use program in 2014. Before sharing our thoughts, let’s focus on what led to these proposed revisions.

In something of a domino effect, delays in the certification of EHR products to 2014 Edition CEHRT have delayed the installations and implementations of updated EHRs for provider organizations. Without the certification, organizations cannot successfully attest to meaningful use in 2014. So, the proposed changes announced by the CMS and ONC suggest providing healthcare organizations the option to participate in the Meaningful Use program by either utilizing the 2011 Edition CEHRT standards, if their EHR does not yet meet the 2014 Edition CEHRT standards, or using a combination of the standards. Come 2015, however, all reporting would still be required to use the 2014 Edition CEHRT.

Another component of the proposed rule is the extension of Stage 2 Meaningful Use through 2016 and the postponement of initiating Stage 3 to 2017, which was included in an effort to encourage the continued adoption of CEHRT by healthcare organizations.

Now, let’s take a step back to our HIMSS14 survey, where 70% of respondents indicated that their organizations had not yet maximized the full potential of Meaningful Use. Shane Pilcher, vice president here at Stoltenberg Consulting, has emphasized time and again that Meaningful Use is a marathon – not a sprint. The reason healthcare organizations that have achieved Meaningful Use are unable to see its full potential is the same reason other organizations struggle to successfully attest: everyone is in the “sprint” mentality.

The changes proposed by the CMS and ONC are not merely offering flexibility – they are giving providers a chance to run the marathon that is Meaningful Use. In the grand scheme of things, we have to look past rules, programs, successes and failures that tend to force healthcare providers into the “sprint” mentality of getting things done to meet requirements, receive incentives and avoid penalties. To push the industry forward as a whole, we have to refocus our perspective on the end goal, which is improving the healthcare system. And if we’d like to arrive at this objective, we need all healthcare organizations, in their varying stages of Meaningful Use, to build a momentum of progress in unison.

As the saying goes, progress is progress, no matter how small. The proposed revisions to Meaningful Use would support such sentiments by allowing all healthcare organizations to maintain their progress in deploying and optimizing their technologies. The successful adoption of EHRs will lay the bricks crucial to building a strong foundation for the improvement of healthcare, which is why a culture of encouragement must be fostered around it for all providers. Clinging to the rigidity of rules and agendas will lead to providers dropping out of the Meaningful Use program and leave them hindered in the journey to deliver better care.

So, the changes proposed by the CMS and ONC should be embraced and implemented – because how successful we are in improving healthcare cannot be measured in terms of those who meet the requirements of a program and those who don’t. It must be measured by the cumulative progress towards the greater goal, by all participants. And at the end of the day, that will be the biggest contributing factor in allowing healthcare organizations and professionals to deliver a new, improved healthcare system.

Quick Tips for Medicaid/Medicare Compliance

Medicare and Medicaid compliance can be a tricky area to adhere to. As such, Senior Consultant, Dick Menard provides the following tips on navigating compliance issues:

Focus on creating process for understanding the requirements as best you can using the proposed rule.  The tricky part is predicting what will change in the final rule, so someone has to monitor the CMS (Centers for Medicare and Medicaid Services) website constantly for updates.  A Google alert works well for this, and there are many special interest blogs that are helpful in interpreting what CMS really intends.  Once the final rule is announced, there is not much time to modify systems.  Also, CMS will issue technical clarifications in publications such as MLN Matters after the final rule has been published.


I suggest making a business requirements document (BRD) using the proposed rule and passing that around to senior hospital management for review.  Sometimes a requirement is so vague that you will have to take a stance and let someone challenge you.  Once you get consensus on what the business requirements are, then you can assess the revenue impact and begin to scope out detail project plans and functional requirements. 

To facilitate moving from business requirements to functional requirements, I recommend creating a business vocabulary.  Make the vocabulary consistent and even color-coded.  This avoids misunderstanding  of what a concept means as more members become part of the team and details stop to emerge.