As healthcare organizations gear up for Year 2 of the Medicare and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP), they should consider what’s changing—and what’s staying the same.
Much of the fundamental structure for MACRA Year 1 will not change, including the “pick your pace” options for participation under the Merit-based Incentive Payment System (MIPS) track. The Centers for Medicare & Medicaid Services (CMS) estimates 90 percent of eligible clinicians will report under MIPS. But in Year 2, MACRA minimizes the short-term impact of the rule for small and rural practices in several ways, including making it easier for clinicians to participate in MIPS.
Expanded Reporting Exemptions
Starting in Year 2, practices with fewer than 200 Medicare Part B patients or less than $90,000 in Medicare Part B allowed charges will not be required to participate. That’s double the number of patients formerly required for participation and three times the threshold for Medicare Part B charges in Year 1, considerably relaxing participation requirements.
“Virtual” Provider Groups
Single practitioners and practices with fewer than 10 eligible clinicians can band together virtually with one other solo practitioner or group to report under MIPS. This move reduces the burden of participation for these groups by enabling small groups to combine their administrative costs for reporting.
Hardship Exemptions in the Advancing Care Information Performance Category
Eligible clinicians who show that demonstrating meaningful use would pose a hardship could gain an exemption valid for one payment year. Up to five hardship exemptions can be granted to an eligible clinician in this or subsequent years.
Several changes will make it easier for small-practice and rural clinicians to claim bonus points under MIPS. CMS will add five bonus points to the MIPS composite score for clinicians in small practices—those consisting of 15 or fewer eligible clinicians—that report data for at least one performance category.
Further, all MACRA-eligible providers could earn bonus points in two areas. Under MACRA Year 2, eligible providers in both the MIPS and advanced alternative payment model (APM) tracks can use 2014 certified electronic health record technology (CEHRT) systems for one more year, but they’ll get bonus points for using 2015 CEHRT systems exclusively. Providers also will get extra points if they can prove they care for especially complex patients (one to three points).
New MIPS Participants
Starting in Year 2, facility-based providers will be able to participate in MIPS. Under this option, a voluntary scoring mechanism is available for facility-based clinicians, such as hospitalists, who perform at least 75 percent of their covered professional services in an inpatient hospital setting or an emergency department.
Eligible clinicians also will be able to initiate the all-payer combination option to determine status as a qualified professional within the advanced APM. This option gives providers in advanced APMs that do not meet the Medicare thresholds an opportunity to include other-payer advanced APMs in their reporting to meet the minimum threshold for performance, thereby potentially helping qualifying APM participants achieve the 5 percent APM bonus. This is important for two reasons: CMS would like to see increased participation in advanced APMs, but participation in APMs is considered a risk. As a result, CMS has relaxed the rules around participation and will reward those that participate by offering a 5 percent bonus each year from 2019 to 2024 to eligible clinicians who meet certain revenue or patient thresholds.
As healthcare leaders, physicians, and clinicians think back on the lessons learned from MACRA Year One, there are two key strategies to keep in mind:
- With so much riding on performance under MACRA, now and in the years ahead, knowing how to best leverage the electronic health record (EHR) for success under MACRA is critical. Look for software capabilities that better support MACRA reporting requirements.
- Continuing to work to close the MACRA knowledge gap also is key: halfway through Year One, an American Medical Association survey found only half of physicians considered themselves “somewhat knowledgeable” about MACRA.
Taking the time now to strengthen MACRA readiness through these strategies will position an organization to put its best foot forward in 2018.
Sonya Bess is a government initiative specialist at Pulse, Inc., Wichita, Kan.