Time certainly flies, and 2018 marks the second year that rheumatologists who see Medicare patients are operating under the new Quality Payment Program (QPP) created by the Medicare Access & CHIP Reauthorization Act (MACRA). MACRA repealed the Fee-for-Service model under the Sustainable Growth Rate (SGR) formula and transitioned Medicare reimbursement to a system more overtly focused on quality and value of care.
The QPP has two pathways in which providers will be reimbursed for their Medicare Part B payments:
- Merit-Based Incentive Payment System (MIPS) and
- Alternative Payment Models (APMs).
Beyond the usual adjustments that are required in response to the Centers for Medicare & Medicaid Services (CMS) and other administrative regulators of our practices, the QPP requires a major shift in how we think about demonstrating value in our practices.
According to the CMS, 5,629 rheumatologists must participate in the QPP in the first performance year.1 The ACR is working to provide options for rheumatologists to use either pathway. The APM represents a more significant change from the traditional payment model, and the ACR has funded the development of a rheumatology APM that is currently in the testing phase. However, at this point, an overwhelming majority of rheumatologists will participate in the QPP via the MIPS pathway. With data requirements increasing for MIPS in 2018, rheumatologists must have a plan in place early for their reporting. Depending on what percentage of your practice is made up of Medicare Part B patients in 2018, the resulting 5% bonus/penalty can obviously be significant.
Rheumatologists can choose various reporting mechanisms to participate in MIPS, and it’s important to note that—among the options—MACRA created incentives for providers to report via registries—including significant bonuses for reporting via a Qualified Clinical Data Registry (QCDR). The ACR has operated its own QCDR, the Rheumatology Informatics System for Effectiveness (RISE), as a member benefit since 2014. RISE helped rheumatologists meet the quality reporting requirements of the now-discontinued Physician Quality Reporting System (PQRS) and can help you meet your current requirements under MIPS.
RISE established a great record of success for rheumatology in the 2017 performance year, and as a result of the increased reporting requirements and rapidly expanding participation in the registry, RISE will be even more valuable for rheumatologists in the 2018 performance year. Early adopters of RISE have demonstrated that they have a significant head start over their other rheumatology colleagues. If you would like to join the RISE registry and use it as your reporting option for 2018, register now.
MIPS scores the care we provide via four performance categories:
- Improvement activities;
- Advancing care information; and
These are combined to generate a final MIPS Composite Score, which CMS uses to assess payment penalties/bonuses.
These performance categories should seem very familiar to most providers; three of these categories are legacy CMS programs: PQRS, the EHR Incentive Program (Meaningful Use) and the Value-Based Modifier (VBM). The fourth category, improvement activities, is a new catch-all for other previous CMS improvement initiatives.
Early Adopters of RISE Benefit Big
As of March 15, 2018, preliminary reports show an 86% increase in rheumatologists who used RISE for quality reporting compared with the final year of reporting for the PQRS program in 2016.
Out of the providers/practices that used RISE for reporting all MIPS categories for the 2017 performance year, almost 17% submitted 100 points (maximum score) to the QPP, and 47% of practices/providers met or exceeded the 70-point exceptional threshold. Out of the maximum 60 points attainable for the quality measures category, the average score for this category submitted to CMS was 49.41.
The average MIPS Composite Score submitted to CMS for users that submitted all MIPS categories with RISE was 88.72 out of a possible 100 points This not only means that practices are obtaining the maximum benefit of this incentive program, but it underscores that rheumatologists are routinely providing high-quality care as defined by the QPP.
MIPS Performance Year 2 (2018)
The CMS estimates that 3,340 rheumatologists are MIPS eligible in 2018. This number is down from the 2017 number because the CMS increased the low-volume threshold for reporting in 2018. For the current year, if rheumatologists have less than or equal to $90,000 in Part B allowed charges or 200 or fewer Part B beneficiaries, then these providers are exempt for reporting into the QPP.2
Another substantial difference for the 2018 performance year is that the maximum payment adjustment for penalties and bonuses increases from 4% to 5%. Other key differences between the 2017 and 2018 performance year of the program are the data requirements for reporting.
The performance threshold increases from three points to 15 points in 2018. This means that providers must submit a MIPS composite score of at least 15 points to qualify for a neutral payment adjustment. CMS did maintain the exceptional performance threshold at 70 points, which is good news for RISE users who were already able to achieve a composite score of 70 or above in the first year. Further, providers had to report on 50% of their patients regardless of payer for any continuous 90 days in 2017, but rheumatologists will now have to report 60% of their patients for the entire calendar year for the Quality category.
Such minutia makes my head spin. However, the good news is that RISE users report high satisfaction with setting up and using the registry in their practices. Significantly, these increased requirements for 2018 will not be onerous to RISE users because the RISE registry reports on 100% of all patients in the Quality category regardless of payer status.
Submitting for 2018
Given the increasing requirements of MIPS, it is important that you have a plan in place for how you will report data for 2018. I encourage you to look into joining the RISE registry and use it as your reporting option. You can register now. If you are already a RISE user and would like to check your status for 2018 or would like to discuss your reporting strategy, you can speak directly with ACR registry staff by emailing RISE@rheumatology.org. ACR registry staff also offers RISE users different avenues and media for support and education so you can stay up to date on how rheumatology providers can best demonstrate their quality care for reimbursement.
I enthusiastically recommend that all ACR/ARHP members take advantage of this member benefit and explore how using RISE can lead to success in the new payment system. This is another example of how, in the ever-changing landscape of policy affecting rheumatology professionals, the ACR is there for you, so you can be there for your patients.
David I. Daikh, MD, PhD, is the 81st president of the ACR. Dr. Daikh serves as the director of the Rheumatology Fellowship Training Program at the University of California, San Francisco and as chief of the Rheumatology Division at the SFVA Medical Center, where he directs the Rheumatology Clinic.
- Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models: Table 58 of the 2017 MACRA Final Rule. Federal Register. 2016 Nov 4.
- Quality Payment Program Year 2: Final Rule Overview. (n.d.).