Practice Management Alert

Stay on top of changes for easier administration and higher reimbursements.

Despite the uncertainty over the Affordable Care Act, one law that isn’t going anywhere is MACRA. The Quality Payment Program of incentives set up under that law to transition Medicare reimbursements to pay-for-performance is going full speed ahead, and your practice is almost certainly very well acquainted with its details (and the challenges that come along with it).

If you participate in the Merit-based Incentive Payment System (MIPS), you should know about important updates recently released by CMS. In response to concerns raised by providers and advocacy groups like the American Medical Association and the Medical Group Management Association, CMS has issued proposed rules for 2018 to make life easier for practices that are burdened by the costs and time demands of MIPS.

What follows is a summary of the major changes, and how they could affect your practice:

Don’t Sweat Software

The 2018 rule pushes certain EHR requirements forward:

• You can still use 2014 edition CEHRT in 2018 — but you’ll receive a ten point bonus on your Advancing Care Information score (which makes up 25% of your total MIPS score) if you upgrade to the 2015 edition. Using the hybrid 2014/2015 edition doesn’t make you eligible for that bonus.
• But keep in mind that the 2015 edition now becomes mandatory in 2019 instead. It’s a delay, not a cancel­lation. Upgrading now will save you time and effort next year, and earn you a bonus in the meantime. The newer edition also contains tools that can help you boost your MIPS score now.

Longer Performance Periods

• The rule proposes 90-day reporting periods for ACI and improvement activities, with a full year for quality and cost measures.

Good Delays

Several requirements are delayed until a future year:

• The Cost Performance category is delayed until 2019.
• Like 2017, 2018 will be another year of easier “transition” scoring, with lower performance thresholds than in future years.

Exceptions for Small Practices

The 2018 rule carves out exceptions for smaller practices that may be burdened by requirements:

• Small practices are eligible for a 5 point bonus. Practices with 15 or fewer individual NPI numbers and a group TIN can take advantage of this bonus.
• The low-volume exclusion from MIPS is tripled, from $30,000 per provider annually to $90,000.
• More EHR workflow exclusions, including an exception from eRx if you write fewer than 100 prescriptions per year, and from the “send summary of care” and “receive summary of care” measures for practices with fewer than 100 patients. This move is retroactive to 2017.
• A hardship exclusion for using CEHRT, available to practices with 15 or fewer clinicians, or to those in rural areas or health professional shortage areas.

Consider Joining “Virtual Groups”

The 2018 rule presents the option for smaller practices to join up and submit MIPS together as a larger “virtual group”:

• Practices with 10 or fewer providers can now enter into agreements to submit jointly, with all participants receiving the same MIPS score.
• Virtual groups offer small or solo practices the opportunity to pool costs and other resources, making it easier and less expensive to aggregate their information. Each practice could end up with higher reimbursements and better patient care than if they went at it alone.
• Joining a virtual group also lowers certain requirements, including those for your ACI base score and your improvement activities.

Use These Transition Years to Get Ready!

These 2018 rules do smooth out some of the severity of the requirements, but it’s important to keep in mind that 2018 will be the final transition year before full implementation. Don’t use that leniency as an excuse to put off preparing your practice.

Mike Schmidt, Director of Compliance and Special Projects for Medflow, advises you to “think of MIPS as a game — your main goal is to practice getting good at the game during these transition years.” Just like any game, MIPS has rules and a scoring system, all of which you can learn and improve at now to get higher reimbursements down the line.

For more information, read the full text of the new CMS rules here: https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-13010.pdf.

For a fact sheet comparing the proposed 2018 rules with previous years, visit: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Proposed-rule-fact-sheet.pdf.