Article by Michael Nusimow, CEO and co-founder of drchrono in Mountain View, CA
Up until now, providers and practice groups have been worrying about Meaningful Use and using their own certified EHR technology to avoid payment penalties, earn incentives, and increase practice efficiency. With the release of the final MACRA rule, physicians now have two options for payment paths: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). MIPS is the consolidation of many different programs and regulations in an effort to simplify reporting and achieve goals that include better health outcomes for patients. Programs that will roll up into MIPS include the Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VBM), and MU, along with the new requirements of showing clinical practice improvement activities.
APMs is the alternative, in which providers can reach out to the AMA and their board specialties to help determine the best way to structure their care to meet the requirements. Following the APM path exempts a provider from the MIPS pathway.
More Background on MIPS
Providers should be aware that PQRS does and will eventually tie into MIPS. CMS will look at some specific key clinical practice activities. These will be the “measures” and/or key performance indicators that providers need to think about during the transition. Clinical practice improvement activities includes processes such as:
- Expanding access to your practice.
- Coordinating care, such as with phone and digital communications.
- Engaging with patients in active care plan participation and shared decision-making.
- Prioritizing patient safety.
Key Dates to Keep in Mind
MACRA went into effect on January 1 (the start of the reporting year) and continues through December 31, 2026, replacing the Sustainable Growth Rate Formula. In 2018, physicians can potentially expect another transition year of reporting and, in 2019, benchmarks and reporting will start to substantially affect reimbursements.
Does This Apply to Physicians?
Prior to 2017, you had to figure out what you qualify for and were required to report based on your specialty, practice setup, and volume of claims made to CMS. For 2017, a low-volume threshold has been set at less than or equal to $30,000 of claims to Medicare Part B and / or less than 100 Medicare patients. Passing over either of these thresholds will qualify you for 2017 reporting.
CMS, in addition to the threshold, has considered the risk to solo and small group practices in making a new reporting group called “virtual group” to allow them to report together. This option is not available for 2017; more information is expected in the future. For practices that are in rural, need-based areas or that are 15 or more providers in a group, additional resources may be available.
How can Physicians Start to Prepare?
A few important points to keep in mind:
- Don’t bury your head in the sand – start communicating with your professional associations to compare and determine how other providers are preparing and how your practice – based on specialty and size – will be affected.
- Be sure to stay tuned to regular updates from CMS and your EHR vendor.
- Providers might be able to opt out of attesting data in 2017, but will receive negative adjustments in 2019. Special assistance and accommodations will be made available to providers in rural settings and larger practice groups.
- Providers can choose between a 90-day and full-year reporting period. Note that most choices of reporting weight bonuses and penalties. MIPS is a program that will work to encourage providers to adopt quickly and with few loopholes or delays.
- PQRS data will be published and used as benchmarks for 2017.
- Providers will not be evaluated on cost or resource use during the first year. Providers are encouraged to track this to help them determine the progress, baseline, and areas of improvement.
- Work closely with your EHR vendor to ensure you understand how to use the product effectively and efficiently – reporting information is only beneficial when it is calculated correctly.
- Even if your EHR is not calculating or ready to start calculating for MACRA in the beginning of 2017, using your EHR correctly will be vital to ensure calculations are useable at a later date.
Common mistakes for larger practices to avoid include:
- Sharing logins: This is not just a HIPAA violation. It will also cause inaccurate credit and penalties to be applied to patient charts and provider calculations. Individuals at the practice should have their own login.
- Starting/signing charts: If your EHR allows charts to be started by one provider and signed off on by another, it is important to understand how that EHR is applying credit and that the appropriate providers are participating as their scope allows.
- Staying up-to-date: Larger practices that fall behind play a constant game of catch up that make it difficult to record all of the necessary information to increase earning potential. Entering backdated information runs the risk of the EHR not calculating information correctly or it being entered inaccurately.
MACRA and MIPS will change the dynamic of many compliance measures, but promises to simplify all recent measures in healthcare to create a value-based healthcare model. Updates on the guidelines will continue to be published from CMS. Make sure you continue to look out for any future updates.