Implications of MACRA for Community Health Centers Russell Kohl, MD, FAAFP Medical Director, Practice Transformation TMF Health Quality Institute CHC Directors’ Summit Thursday, Jan. 19, 2017 Austin, TX

Most of these slides are shamelessly borrowed from CMS

MACRA Effect on CHC Funding The ACA funded CHCs $11 billion from 2011 to 2015 MACRA, Section 221: Extension of Funding for Community Health Centers, the National Health Service Corps, and Teaching Hospitals Funding for the Community Health Center (CHCs) program and the National Health Service Corps (NHSC) was set to expire at the end of September 2015. MACRA extends funding for these programs through fiscal year 2017 Keeps the funding amounts for fiscal year 2016 and 2017 at the current fiscal year 2015 level Extends funding through fiscal year 2017 for the Teaching Health Center Graduate Medical Education Payment Program Provides $60 million for direct and indirect graduate medical education (GME) payments to teaching health centers. Subjects the 2016 and 2017 funding to Public Law 113-235, which restricts the use of these funds for abortion services.

Quality Payment Program Objectives Improve beneficiary outcomes and engage patients through patient- centered Advanced APM and MIPS policies Enhance clinician experience through flexible and transparent program design and interactions with easy-to-use program tools Increase the availability and adoptionof robust Advanced APM’s Promote program understanding and maximize participation through customized communication, education, outreach and support that meets the needs of the diversity of physician practices and patients, especially the unique needs of small pratices Improve data and information sharing to provide accurate, timely and actionable feedback to clinicians and other stakeholders Ensure operational excellence in program implementation and ongoing development

For FQHCs, it is important to note that MACRA/QPP implementation will not impact your Medicare FQHC PPS payments. Because health centers are paid their unique Medicare PPS and are not paid on the Physician Fee Schedule (“Part B”) they will not be subject to MIPS and their payment methodology will not change. Health centers will be able to voluntarily report under the new MIPS, without incentive or penalty. There is one exception: services that are billed outside of the FQHC benefit and billed to Medicare Part B separately are subject to MIPS.

Low Volume Threshold Impact on FQHC’s For those FQHCs that have providers that bill Medicare Part B separately and outside of the FQHC PPS rate, those individual providers may be subject to MIPS. Medicare Part B billing <$30,000 annually OR see <100 Medicare patients. Medicare volume is below threshold and are not subject to MIPS.

FQHC Participation in Advanced APM’s FQHC visits can count toward a Qualified APM Participant’s (QP) patient count and thus a participating FQHC could be eligible for the “bonus payments” in an APM model. Additional details are to be determined at the APM level and subject to CMS approval.

Advanced APMs Comprehensive ESRD Care (ECC) Model* Comprehensive Primary Care + (CPC+) Model Medicare Shared Savings Program ACOs, Track 2 & Track 3 Next Generation ACO Model Oncology Care Model (OCM)* Vermont Medicare ACO Initiative

MIPS Component Scores

MACRA provisions call for RHC and FQHC claims submitted to Medicare Part A to be able to report QPP data voluntarily, and there will be no payment adjustments for claims submitted under these provisions.

https://qpp.cms.gov/measures/quality

Questions? Russell.Kohl@TMF.org