The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), enacted April 16, 2015, required the Secretary of Health and Human Services (HHS) to establish a new Merit-based Incentive Payment System (MIPS) to assist the Centers for Medicare & Medicaid Services (CMS) in accelerating the transition from the traditional fee-for-service payment model to a system that aims to reward healthcare providers for value rather than volume of services provided. The new system includes combined components of the Physician Quality Reporting System (PQRS), the Value Modifier (VM or Value-based Payment Modifier), and the Medicare Electronic Health Record (EHR) Incentive Program into one single program renamed the Quality Payment Program (QPP) — previous programs that many physicians may recognize as part of their practices.
The QPP has “re-packaged” these programs to assess the performance of MIPS-eligible clinicians based on four performance categories: (1) Quality, (2) Cost, (3) Clinical Practice Improvement Activities, and (4) Advancing Care Information (certified EHR technology). Each category carries a weighted value based on a 1 to 100 point scale. A final score will determine an adjusted Medicare payment starting in 2019.
For a comprehensive explanation on the four categories, visit this link.
In the process of implementing MIPS, a major point of contention was how burdensome the requirements would be on solo and small group physicians and, as a result of the strong push back, HHS and CMS have made continuous changes to help alleviate the burden and make minimum requirements accessible. One major update to the initial rule was the threshold for MIPS eligibility. CMS wants to exempt more small providers from having to comply with MACRA and in June changed the rule to exempt physician practices with less than $90,000 in Medicare Part B revenue or see fewer than 200 unique Medicare patients per year. Some may welcome the opportunity for exemption, but others have started to solicit CMS to consider giving small practices who would still want the option to pursue bonus payments by electing to participate in MIPS.
All these changes represent the first comprehensive update to the federal healthcare program in decades and as such, it is not unusual that many eligible physicians have delayed adopting the new system. We are now less than four months away from the end of the initial 2017 reporting year and a recent American Medical Association study found that one in four physicians interviewed said they were not prepared to meet statutory requirements this year. For these physicians, it could mean they will face a financial penalty in 2019. It is important to keep in mind that important deadlines will soon be approaching but something can still be done to avoid penalties.
As a reminder, several options became available to provide physicians with the flexibility to “pick their pace” for the reporting program they wish to participate in this year. Following is the link to see a list of the four options to help you determine what your best option is if you have not yet started tracking: http://www.aafp.org/practice-management/payment/medicare-payment/pick-your-pace.html
On the application side of this equation, physicians primarily need to comprehend the workings of MIPS in order to bring themselves into compliance and potentially to greater benefit from the enhanced reimbursement incentives built into the program. There have been many bumps getting the program off the ground and more changes continue to be proposed, considered, and adopted by CMS, particularly those involving solo and small practice physicians.
Another effort by CMS to support the solo and small group practices was to award grants to 11 community-based organizations across the country to provide on-the-ground training and education about the QPP. The Health Services Advisory Group (HSAG) was the organization selected to assist physicians in California. HSAG offers multiple tools such as an online library, a live helpline, printed materials, webinars, and one-on-one assistance to physicians who contact them. With consultation, they are prepared to assist with identifying the quality measures best tailored and most point-effective for each individual practice—all free of charge.
Looking at all the multiple components of the QPP and putting together the right pieces that best reflect your practice will create a pathway through which successful compliance may be achieved. Deciding to participate in MIPS is not as overwhelming as it seemed initially.
Please visit the links below to learn more about the resources available to you.
MACRA Resources
HSAG: https://hsag.com/en/medicare-providers/quality-payment-program/
LACMA: https://www.losangelesmedicine.org/macra-update-cms-proposal-exemption/
CMA: http://www.cmanet.org/issues-and-advocacy/cmas-top-issues/macra/
Modern Healthcare MACRA Guide: http://bit.ly/2wbDvxJ
CMS QPP Website: https://qpp.cms.gov/