Clinicians who enroll in Medicare for the first time during a performance period are exempt from reporting on measures and activities for MIPS until the following performance year. In addition, any clinicians who fall below the low-volume threshold (i.e., have Medicare Part B allowed charges less than or equal to $30,000 or who have 100 or fewer Medicare Part B patients) are also exempted. Finally, clinicians who significantly participate in advanced APMs are exempt.
When
The implementation of MACRA has been a long process, commencing with its passage in April 2015. On Oct. 14, 2016, the CMS announced the final regulations and offered physicians the option to “pick their pace” for participating in QPP during the transition year, which commenced Jan. 1, 2017. The first option was a test pace, pursuant to which physicians submit some reportable data after Jan. 1, 2017. Physicians who chose this route were deemed eligible for a neutral or small payment adjustment.
The second option was partial-year participation, in which physicians would report for a continuous 90-day period after Jan. 1, 2017. In return, these physicians would receive a small positive payment adjustment.
The final option was full-year participation, pursuant to which physicians would fully participate starting Jan. 1, 2017. These physicians would receive a modest positive payment adjustment in return.
It is worth noting that physicians who refused to participate in the QPP for the transition year will receive a negative 4% payment adjustment.
On Dec. 31, 2017, the first performance period closed for all providers, and performance data must be submitted to the CMS by March 31, 2018. The CMS intends to provide feedback on the data received.
On June 20, 2017, the CMS released its proposed rule updating the QPP for CY 2018. That rule proposed an expansion and extension of the flexibility offered to practitioners in the 2017 performance period into the 2018 performance period. The proposed rule would expand the group of practitioners in the low-volume threshold from under $30,000 in Medicare Part B charges or less than 100 Medicare Part B patients to under $90,000 in Medicare Part B charges or less than 200 Medicare Part B patients. In addition, the proposed rule would continue a modified version of the “pick your pace” approach to MIPS-participating clinicians.
On Nov. 2, 2017, the CMS issued the final rule for CY 2018. The final rule includes policies to reduce the administrative burden placed on providers by clarifying the details on many aspects of the program, including the APM scoring standard. In addition, CMS is decreasing the number of clinicians required to participate in QPP. There is also a new hardship exception to assist small practices and clinicians affected by natural disasters, such as Hurricanes Harvey, Irma and Maria. Finally, the final rule included the flexibilities that were in the proposed rule.
What Do I Do Now?
Although the QPP program for CY 2018 grants continued flexibility to program participants, the program is still expected to commence as initially planned in 2019. Therefore, reporting providers should spend time now carefully evaluating their practices and improving their performance in the MIPS measurement areas. Recommended tips include the following:
- Review the CMS’s list of proposed quality improvement activities and determine whether your practice and patients would benefit from implementation of any additional strategies.
- Review prior PQRS performance measures, and determine your practice’s weaknesses. Invest time now correcting those weaknesses and improving your practice’s strengths.
- If you will be seeking scoring as a virtual group under MIPS, begin preparing for this possibility by preparing a formal written agreement between each member of the virtual group. Virtual groups can comprise solo practitioners and groups of 10 or fewer eligible clinicians who come together virtually to participate in MIPS for a performance period. Certain rules and definitions apply.
- If you have not done so already, consider updating your practice’s EHR to a platform that is considered 2015 Certified Electronic Health Record Technology.
QPP is an extremely detailed program and can be an administrative nightmare if you do not begin preparations now. Maximize your chances of positive payment adjustments and begin preparing now.
