This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.
Last week on Friday, we posted the various resources available for the MACRA Final Rule. As you can imagine, one weekend isn’t nearly enough time to process what’s in the final rule. It’s going to take weeks to really get through it all. In fact, we might take a few weeks off from MACRA Monday to process it all.
That said, we wanted to do a quick post this MACRA Monday to talk about the new eligibility requirements and thresholds in the MACRA final rule. For reference, here’s our previous post that looked at MIPS eligibility in the MACRA proposed rule.
In the final rule, it looks like there are still 3 categories of exceptions: new doctors, low medicare volume and participation in an advanced APM. The big change in the MACRA final rule is what is considered low medicare volume. In the proposed rule it said, “$10,000 and providers care to 100 or fewer Medicare patients in a year.” Note the “and” in that requirement. In the MACRA final rule it excludes doctors with less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients.” Note the “or” and the move from $10k in Medicare volume to $30k in Medicare volume.
With these three exceptions, Andy Slavitt sent the following tweet:
KEY STAT: More than 1/2 of physicians in practices under 10 will be excluded from MIPS because not enough Medicare, new or in Adv APM.
— Andy Slavitt (@ASlavitt) October 14, 2016
I quickly commented, “Now you’re going to get the small practices complaining that they were excluded from the incentives. #MACRA #CantWin” CMS’s MACRA executive summary says that they considered allowing those that were below these levels to opt into MIPS if they desired, but they “determined that it was inconsistent with the statutory MIPS exclusion based on the low-volume threshold.” I think the complaining for not being allowed to participate will be pretty minimal. 4% of such a small volume of Medicare won’t be that impactful for most.
There’s the start of our analysis of the MACRA final rule. A good first step to knowing if you qualify to participate in MACRA. Let us know if there are changes in the final rule that you’ve noted or that are bothering you. We’d love to hear them in the comments.
Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.