Chances are, most physicians today aren’t thinking about MACRA or how it will affect them. The yearlong flexibility period, accommodations made for small practices and exceptions from MIPS granted by CMS – along with a general lack of education and information on the matter – have lulled care providers into a comfort zone of sorts. But in this case, ignorance certainly is not bliss. Don’t forget that the MACRA/MIPS flexibility period begins January 1, 2017 and ends January 1, 2018 … and it’s just that: a temporary period. Requirements and payment adjustments will only become more and more rigid in the coming years. Eligible clinicians and staff members will benefit from preparing for MACRA now and educating themselves on MIPS and how it will affect their practices.
Below are the questions and answers from our most recent MACRA Webinar: A MIPS Deep Dive.
Have any more questions or comments of your own? Please leave them in our comment section at the bottom of the page.
QUESTIONS AND ANSWERS:
How do we enroll in MACRA with CMS and when does that need to be done?
Providers don’t need to enroll in the program, they just need to submit their performance information to CMS. The first reporting submission period begins January 1, 2018.
Our providers have not performed Meaningful Use for the past two years because it was a burden to our practice. We have continued to do PQRS but not MU. Will this affect them with the new ACI program?
No, the programs and their associated penalties start anew each year, so past performance is irrelevant.
What deductions is a doctor, who never participated, getting right now as far as PQRS and Meaningful Use combined goes? Can we start either program this year or we just start MIPS?
Medicare physicians in groups with more than 10 physicians will face a 10 percent non-compliance penalty for MU and PQRS in 2018 based on performance in 2016. Medicare physicians in groups with less than 10 physicians will face a 8% non-compliance penalty for MU and PQRS in 2018 based on performance in 2016.
If the physician does not utilize an EHR can we report these on claims? Do we report for only 90 days in 2017? Do we only report this for Medicare patients? What about patients who have a Medicare HMO/PPO plan?
2017 reporting requires a minimum of 90 days and MACRA does only apply to traditional Medicare part B services under the Physician Fee Schedule, which does not include Medicare patients with a HMO/PPO plan (which is Medicare Advantage.)
Who am I compared to?
CMS will set performance thresholds based on the CPS (Composite Performance Score) for all MIPS clinicians for a previous period. Your composite performance – or total score – will be compared to this threshold to determine your payment adjustment amount.
Are the MIPS Quality score benchmarks available on a per measure basis yet? When will they be available?
They are not yet available and CMS has yet to indicate when they will be.
Who Is Exempt From MIPS?
Providers participating in Medicare Part B for the first time (in their first year), qualifying Advanced Payment Model Participants, and individuals or groups with less than $30,000 per year in Medicare Part B billings, or 100 or fewer Medicare patients per year.
Regarding Health Information Exchange: Does this exchange include (besides physician) referral to hospital (patient admission to the hospital), referral to nursing homes, referral to home care and referral to another clinic (ei: lab work or ekg)?
Labs and imaging, no. Those aren’t referrals under MU/ACI. Referrals to other settings of care should include referrals to a hospital outpatient care setting, like a surgery center. But I don’t think hospital or nursing home admissions are referrals in this context. Healthfusion’s product team should know how you calculate this denominator and whether it includes a hospital admission. You might ask them to clarify.
Are the six Advancing Care Information measures on every single patient we see, or only a certain population?
All MU/ACI measures apply to all patients, mostly those seen during the reporting period, but there are some exceptions. In no case is it distinguished by insurance.
Are the measures for office visits only? Will home visits count towards the measures?
Generally visit codes include all the E&M visit and consult codes, and I don’t see why home visits would be excluded.
Can I participate without an EHR?
Clinicians without an EHR can still participate in MIPS, but will gain 0% under the ACI performance category. This will negatively affect the clinician’s total composite score. And while still possible, the reporting requirements will be more burdensome without the use of an EHR. The reporting mechanisms available to a practice without an EHR would be claims or qualified registry. However, use of the qualified registry option would require a manual data collection process. As proposed, this would require reporting on at least 90 percent of the clinician’s denominator-eligible patients.