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MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.

MACRA Twitter Roundup – MACRA Monday

Posted on October 30, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

We took last week off from our MACRA Monday series of blog posts. It seems like we’re in a kind of lull period for the program. Either you’ve started collecting the data you’ve needed or you haven’t. Plus, we’re kind of waiting for the next MACRA Final rule to drop for more details.

With that in mind, I did want to see what some of the latest things that were being shared on Twitter when it comes to MACRA. I found a lot of strong opinions about the program, some good resources, and some forward-looking thoughts on what could be coming in the next MACRA final rule.


It’s hard to argue with John. Not just because he’s a smart guy, but because he’s right that it’s hard to imagine a path forward that’s fee for service and doesn’t include a shift to value based care in some form or fashion. At least given the current market dynamics.


This caution from Workflow Chuck should have us all nervous about the shift. I see a lot of healthcare organizations going after the target as opposed to the goal of value based care.


MACRA is going to impact your biz. I liked the way Kelly broke it out into 4 areas. No doubt some of these things could be argued both ways.


This is still how most doctors I know feel about MACRA and even meaningful use before it. They feel like they’ve been thrown under the bus.

Here are two forward looking resources that look at what we might get from the MACRA Final Rule:

What else are you hearing about MACRA? Would love to hear your thoughts, insights, questions, perspectives, rants, etc in the comments.

Optimizing Your EHR for MIPS and Other Quality Payment Programs – MACRA Monday

Posted on October 9, 2017 I Written By

The following is a guest blog post by Meena Ande currently acts as Director of Implementation for Advantum Health. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

As quality reporting requirements ramp up under value-based payment programs like MIPS, healthcare organizations are busy retrofitting their EHRs to make way for new measures. In some settings, not much has changed by way of tech utilization since initial EHR investments were made. Many outpatient settings still lack the internal expertise needed to optimize their implementations.

The truth is many EHRs have the functionality providers need for quality reporting, but many providers don’t know that due to limited exposure to the system. Couple that stunted tech knowledge with the well documented lack of familiarity with MACRA and the recent rise of the service model in healthcare is no surprise. Many practice administrators are relying on their EHR vendor or engaging outside experts to help lead the charge on system reconfiguration to meet Quality Payment Program demands.

There are several EMR capabilities providers can take advantage of to support QPP reporting efforts. Here are a few tips to keep in mind as you customize your EHR for MIPS and other value-based models.

Don’t boil the ocean when selecting CQMs.

Most EHRs give the option of tracking more than what is required for quality reporting. Initially, track applicable measures that exceed reporting requirements. After three to four weeks you’ll know which are your strong areas. Pick the best of the litter and proceed.

Providers can be overwhelmed by too many measures, particularly in multi-specialty practice settings. While it can be difficult to find overlap in measures between specialties, taking advantage of shared metrics whenever possible can reduce reporting burdens. Sit down as early as possible and develop an EHR configuration that works for your practice’s various clinicians.

Case in Point:

A gastroenterologist and a cardiologist may work in the same multi-specialty organization and on the same EHR, but the clinical quality measures they care about differ. There is no reason to give the gastroenterologist access to the cardiology problem list in the EHR. Specialty views improve ease-of-use and support more complete documentation.

Most EHRs offer role-based and specialty-based customization. Administrators can enable or disable EHR features related to some quality measures at the practice level and sometimes at the individual provider level. Clinical quality measures are based on details about the patient, but what is captured at each point of care should be tailored to the specific provider role.

Consider the roles impacted by different CQMs.

Keep the role of the person who may be responsible for different quality measures and Advancing Care Information workflows in mind when selecting and carving out space for CQMs in your EHR. Select measures that spread reporting work across multiple roles to relieve clinicians of unnecessary burdens.         

Case in Point:

The insurance eligibility verification required under Meaningful Use is managed by the front office. Front-office staff members should be made aware of the processes they need to complete before a patient checks in, and where to document that task in the EHR.

Control what is included in MIPS denominators.

Like Meaningful Use, patient encounter volume is important under MIPS. The size of the patient pool under any given quality measure directly impacts your adherence percentage. While most primary care encounters do meet patient visit requirements under MACRA, that is not always the case in specialty settings. Clinicians can exercise some control in determining what is included in patient denominators when reporting under MIPS.

Case in point:

Some primary care visits can be omitted. Let’s say a two-physician practice sees 50 patients a day. Only 15 of those patients might be seen by a physician. The rest of the patients may be there for a simple procedure like a blood pressure screening, stress test, or echocardiogram, where quality reporting elements are not verified. Such visits should be excluded.

Evaluate your reporting paths.

MIPS offers both EHR-based and registry-based reporting paths. Most specialties can submit CQM data via their EHR while others will have to rely on paid registry reporting. Additional reporting options might include submitting through associations that member clinicians are affiliated with, or through registries created by large hospital affiliates to help related providers.

Another hurdle for clinicians is deciding whether to submit data as a group or independently. Groups interested in participating in MIPS via the CMS web interface or administering the CAHPS for MIPS survey had until June 30, 2017, to register. Beyond that, clinicians have until the March 31, 2018, MIPS submission deadline to decide whether to report independently or as a group.

Case in point:

Big groups with different levels of EHR proficiency among providers may be better suited reporting at an individual level. Individual reporting takes more time for attestation, but the advantage is that higher-performing clinicians can avoid a penalty if the group doesn’t collectively meet reporting criteria.

Each month, sample 10 percent of EHR CQM data, including instances where criteria have been met and where it has not. Catch outliers with trouble following through on processes and extend targeted training to the team members bringing numbers down.

Conclusion

Optimizing the EHR and other tech resources providers have in place can be a huge MIPS enablement factor. Up-front customization work helps providers meet reporting requirements and save time over the long run. EHR optimization also enables future value-based care initiatives and lays the groundwork for population health management programs. Gains made in EHR use benefit the life of the practice through increased efficiency and, at the end of the day, better patient care.

About Meena Ande
Meena Ande currently acts as Director of Implementation for Advantum Health where she manages Implementation of services along with EHR optimization, with emphasis on workflow management for value-based reporting.

Why Delaying the Transition to 2015 Edition Technology Would Be a Problem for Patients and Families – MACRA Monday

Posted on September 11, 2017 I Written By

The following is a guest blog post by Erin Mackay, Associate Director, Health Information Technology Policy and Programs, National Partnership for Women & Families.  This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

The National Partnership for Women & Families recently weighed in on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for 2018 updates to the Quality Payment Program (QPP). In our comments, we express concerns that many of the proposed requirements would have a chilling effect on the country’s badly needed transition to a health care system that rewards quality and value over volume. Of particular concern to us is the proposed delay in clinicians’ transition to the 2015 Edition electronic health record (EHR) certification requirements.

Putting off requirements to use more advanced health IT would be a one-two punch to health transformation. First, new models of care that demand high-quality, efficient practices and coordinated care rely on robust health IT. Likewise, these new models only succeed when patients have the information – about their medications, health status, diagnoses and treatment received – they need to participate in their care and make informed decisions with their health care teams.

Here are three ways the proposed rule would delay critical functionalities that are foundational to a patient and family-centered health care system:

1) Delaying Availability of APIs for Consumer Access
It would undermine the commitment to patient engagement to delay the availability of application programming interfaces (APIs) as a way for patients and their caregivers to access, download and share health data. When available, APIs will let consumers choose from a range of apps that pull in health data from various health care providers and hospitals, helping form a comprehensive picture of their health and health care and facilitating information sharing. Gone will be the days when patients and family caregivers struggled to remember passwords for multiple patient portals, or were able to view only one aspect of their medical history at a time.

2) Slowing More Robust Collection of Demographic Data
To enhance health equity, we must first be able to identify disparities by gathering standardized, granular demographic data. Right now, certified EHRs are not designed to distinguish among Chinese, Indian or Vietnamese patients, for instance, instead collapsing these identities into a single “Asian” category. Similarly, EHRs cannot currently store structured information about patients’ sexual orientation or gender identity. In both these examples, this information has clinical relevance and is vital for improving health outcomes. For example, too often transgender individuals do not receive appropriate “gendered” preventive screenings such as Pap tests, mammograms and prostate exams.

3) Failing to Capture Information on Social Determinants of Health
In addition to better demographic information, to best support providers in delivering patient- and family-centered care, EHRs should also capture information about non-clinical factors pertinent to individuals’ health. The 2015 Edition includes a new criterion to capture relevant social, psychological and behavioral data. This includes information on financial resource strain, educational attainment, stress, depression, physical activity, alcohol use, social connection and isolation, and intimate partner violence. At the individual level, this information could help clinicians and care teams determine treatment options that address the unique needs of the patients and families they serve. To improve population health, clinicians, hospitals and community organizations need this information to identify communities that need additional support in order to get and stay healthy.

Conclusion
Overall, the proposed rule for QPP 2018 raises a number of concerns for the National Partnership, particularly the proposed delay of 2015 Edition certified health IT products. We strongly encourage CMS to maintain the current requirements and timeline for clinicians transitioning to the 2015 Edition to provide the necessary infrastructure for the kind of patient- and family-centered health system our country urgently needs.

MACRA Monday: MIPS Imposes A Major Burden

Posted on August 28, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

A new study by the Medical Group Management Association has concluded that most practices find participating in the MACRA Quality Payment Program to be very challenging. The study, which focuses on regulatory burdens affecting group practices, also identifies several other rule-related challenges practices face.

In its press release, the MGMA notes that almost half of practices surveyed said they spent more than $40,000 per FTE physician each year to comply with various regulations. Nonetheless, they continue to participate in programs that reward them despite the hassles involved.

According to the research, the vast majority of respondents are participating in the Merit-Based Incentive Payment System (MIPS) this year, and 72% said they expected to exceed the minimum reporting requirements.

That being said, their success clearly hasn’t come easily, with 82% of practices rated MIPS as either “very” or “extremely” burdensome. Within MIPS, groups cite clinical relevance (80%) as their top challenge. Seventy-three percent of survey respondents said MIPS doesn’t support their practice’s clinical quality priorities.

In fact, many respondents said that complying with MIPS was like pulling teeth. Over 70% reported that they found the MIPS scoring system to be very or extremely complex, and 69% said they are very or extremely concerned that unclear program guidance will impact their ability to participate in MIPS successfully.

Eighty-four percent of respondents agreed or strongly agreed that if Medicare’s regulatory complexity were reduced, they could shift more resources to providing patient care. Their frustration is palpable, as the following anonymous comment illustrates: “The regulatory and administrative burdens have dramatically increased over the past two years. However, the biggest problem isn’t the increase itself, [it’s] that the increase is for no good purpose.”

Other programs respondents named as very/extremely taxing included national electronic attachment standards (74%), audits and appeals (69%) and lack of EHR interoperability, followed by payer use of virtual credit cards (59%).

It’s interesting to note the disconnect between the number of practices participating in MIPS (and seemingly, crushing it) and the complaints most are making about participation. Clearly, given how painful it can be to comply with the rules, most practices see their involvement as necessary from a financial perspective.

It’s unlikely that this participation it will get much easier in the near future, though. Eventually, as regulators keep taking feedback and streamlining the MIPS program, they may be able to streamline its requirements, but I wouldn’t hold my breath waiting for that to happen.

The Health Plans’ Role in Meeting MACRA Requirements – MACRA Monday

Posted on July 17, 2017 I Written By

The following is a guest blog post by Karen Way, Health Plan Analytics and Consulting Practice Lead at NTT DATA Services. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

When the Medicare Access and CHIP Reauthorization Act (MACRA) became an official federal ruling for the healthcare industry in 2015, the act replaced the previous Medicare reimbursement schedule with a new pay-for-performance program focused on quality, value and accountability. In short, the legislation rewards healthcare providers for quality of care, not quantity.

While many discuss the impact on providers, what is the health plans’ role in aiding health systems and physicians to meet MACRA requirements?

MACRA provides multiple opportunities for health plans to increase and improve collaboration with provider networks. Recommendations on how health plans can accomplish this include sharing information and services, creating new partnerships and bringing about financial awareness as the legislation continues to take effect.

Sharing Data

One of the requirements under MACRA is for providers to enhance clinical measures and data analytics to strengthen members’ experiences. Health plans can assist by recognizing where providers lack expertise in data-related facts to offer input and support where it’s most beneficial.

For example, a provider may not have as much knowledge on advanced data science, but health plans can share their predictive models and tools to strengthen analytics. Sharing advanced technical infrastructure to facilitate data exchange will enable providers to access a more complete picture of members’ profiles. In return, the picture will provide a higher quality service to individual members, as well as opportunities for health plans to continue offering tailored consulting and data support.

At its best, sharing data to improve clinical measures is a win-win scenario. The Healthcare Effectiveness Data and Information Set (HEDIS) is a tool used by more than 90 percent of America’s health plans to measure performance on important dimensions of care and service. Just as HEDIS calls for measurement, MACRA also encourages health plans to aid providers with reporting standards. Under these rules, health plans are required to record a wealth of information on members, and when shared with providers, the tide lifts all boats.

Partnering to Manage Risk

Some of the changes under MACRA are reminders for providers to be highly aware of risk management. Providers will seek strong partners with the necessary skills, experience and knowledge to ensure they do not take on risk greater than they can support. To assist, health plans should enter into risk-sharing relationships, such as value-based contracts, with high-performing providers.

Health plans should actively strive to be strong partners by enabling robust data analytics that support quantitative action plans in the areas of quality and clinical care gaps, medical cost and trend analysis, population health, as well as member-risk management. As health plans partner with providers, they should also stay flexible on potential changes to provider payments as the pay-for-performance model(s) mature over time.

Financial Awareness

Health plans also need to be aware of the financial considerations that result from increased value-based contracting for small and large providers.

Under MACRA, smaller providers and individual physicians are more likely to be exposed to potential increase in costs, which may result in additional provider considerations. As Medicare payments shrink, these providers will look to shift costs to other payers, making contract negotiations more difficult and potentially increasing unit costs for some services. Large physician groups, or those located in markets with progressive healthcare systems, will look to negotiate even higher reimbursement rates due to the potential for increased competition.

Health plans should also be aware of potential impacts beyond Medicare fee-for-service (FFS), which is the initial focus of the MACRA legislation. Pay-for-performance is likely to extend beyond Medicare FFS into other health plan lines of business, such as Medicaid or commercial plans. For example, under MACRA, Centers for Medicare and Medicaid Services stated it would consider permitting Medicaid Medical Homes to count as an alternative payment model if participating practices would risk at least four percent of their revenue in 2019 and five percent in 2020.

Why This Matters

Overall, MACRA creates a tall order as it aims to increase pay-for-performance and decrease care based on quantity. This notion is an altruistic adjustment for the health system and each party has a specific role to play to achieve the dream. But the backbone of this goal is collaboration between health plans and providers. Collaboration will result in shared clinical measures, awareness and management of risk, lower healthcare costs and, most importantly, improved patient outcomes.

The Top Three Hidden Impacts of MIPS – MACRA Monday

Posted on July 10, 2017 I Written By

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust

Independent Primary Care Practice Success and MACRA – MACRA Monday

Posted on July 3, 2017 I Written By

The following is a guest blog post by Christina Scannapiego who currently writes the technical documentation and educational content for HealthFusion MediTouch. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

Can participating in a PCMH and programs like Chronic Care Management improve your MIPS total score?

The shift to fee-for-value healthcare may feel like discouraging, foreign territory. However, if you’re already participating in value-based models like a patient centered medical home or chronic care management, your practice is more poised for success during this transition.

Chronic Care Management

The Centers for Medicare and Medicaid Services (CMS) have increased reimbursement for Chronic Care Management (CCM) services. Now, a provider has the potential to earn more than $50,000 per year under the CCM program. Patient-centered care, patient engagement and better care coordination are the core objectives of CMS. Participation in CCM could weigh heavily on your total MIPS score. CCM helps patients by extending care support beyond face-to-face appointments. Participation in this program will help you move the needle in four performance categories by extending care between office visits, controlling costs, increasing care coordination, enhancing doctor-patient relationships to help improve patient outcomes.

CCM and MACRA overlap across several MIPS components:

  • Advancing Care Information: Previously Meaningful Use, meant to achieve patient engagement and promote the electronic exchange of information, practice analytics and reporting capabilities using an EHR.
  • Quality measures: At least 30 measures including many high priority items are common to the CCM program.
  • Clinical Practice Improvement Activities: Patient engagement is one of the main objectives of both CCM and MACRA. Providing 24/7 access to clinicians and coordinating care across provider settings plays an integral part in the CCM objectives and will boost your score in this performance category.
  • Cost: Although providers aren’t responsible for reporting data in this performance category, participating in CCM can lower costs due to preventable hospitalizations from poor medication adherence and care transitions to other providers. Patients with multiple chronic conditions can often pose the highest costs in healthcare. Effectively managing the care of patients will ultimately benefit their overall well-being and the health of your practice.

Patient Centered Medical Home

The PCMH model was established to help deliver patient-centered care through care coordination, preventative services, population health management and extended access to care services. This model thrives from robust patient engagement, which is one of MACRA’s most important goals. MIPS scoring methods favor those participating in PCMH by automatically scoring providers with 100% in the Advancing Care Information performance category. PCMH recognized practices will also likely get credit in the Advancing Care Information performance category because of their experience with NCQA standards.

The importance of both CCM and PCMHs in the new healthcare regime have placed primary care physicians in a unique and opportune position; one in which the independent provider stands to find success amidst change. The impact of MACRA on healthcare is “monumental” and “herculean,” said the Director of Provider Innovation Strategies at DST Health Solutions in her presentation, “The Role of PCMH Under MACRA.” MACRA isn’t a momentary, passing legislation — it’s had bipartisan support from the beginning and it’s here to stay. Luckily for PCHM and CCM participators, this new legislation and enormous impact becomes more manageable.

About the Christina Scannapiego:
Christina Scannapiego has been a technical, health and lifestyle writer for more than 10 years. Christina currently writes the technical documentation and educational content for HealthFusion MediTouch, an Electronic Health Records software platform. HealthFusion and its MediToch cloud software suite is a subsidiary of Quality Systems/next Gen. MediTouch is comprised of a range of web-based software solutions for physicians, medical practices and billing services.

2018 QPP Proposed Rule: What it Means for MIPS & Quantifying the Impact on Specialty Practices – MACRA Monday

Posted on June 26, 2017 I Written By

The following is a guest blog post by Justin Barnes, Board Advisor at iHealth Innovations. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

The Centers for Medicare and Medicaid Services (CMS) recently released a Proposed Rule highlighting recommended updates to the 2018 reporting period of the Quality Payment Program (QPP). Like flexibilities extended in 2017, the proposal seeks to further reduce reporting burdens on small practices and rural providers in the program’s second-year reporting period.

Merit-based Incentive Payment System (MIPS) reporting track updates include:

  • Increased low-volume exemption thresholds (<200 patients or <$90,000 in payments)
  • New virtual group options for solo practitioners and groups with 10 or fewer Eligible Clinicians
  • Extending “pick your pace” flexibilities into 2018
  • Postponing introduction of the Cost category to MIPS composite scores
  • Factoring MIPS performance improvements into quality scores
  • Permissions for facility-based providers to report through the facility where they do most of their work instead of the practice
  • Permitting the use of 2014 CEHRT in 2018 reporting

The Rule introduces new MIPS bonus point opportunities for:

  • The use of 2015 CEHRT
  • The care of complex patients

Recommendations also extend small practice relief including:

  • Up to 5 bonus points for practices with 15 or fewer Eligible Clinicians
  • Hardship exemption for Advancing Care Information category measures
  • Additional points on Quality measures that don’t meet completeness requirements

Comments on the Proposed Rule are due by August 21, 2017. Physicians have until October 2, 2017, to begin collecting performance data for the inaugural 2017 MIPS reporting period.

Calculating MIPS: The Financial Impact on Specialty Practices

Results from a crowdsourced survey fielded by Black Book Research among nearly 9,000 physician practices from February through April of 2017 reveal that 94 percent of physician participants were unaware or unsure of how to predict their 2017 MIPS performance scores. Seventy-seven percent of practices with three or more clinicians reported intentions to purchase MIPS compliance technology solutions by the fourth quarter of this year, largely driven by an inability to independently determine earning potential under MACRA.

Orthopedics, cardiology and radiology are among the highest incentivized specialties under MIPS. To help specialty practices quantify the fiscal impact MIPS poses, we evaluated average Medicare earnings by specialty to establish the MIPS calculations below. These estimates are based on bare minimum earnings and losses that could be greater for practices with larger Medicare patient populations and/or more physicians. (Calculations are strictly illustrative estimates.)

Cardiology Practices
Estimated average payment adjustment for a 5-clinician cardiology practice in 2019 alone: $43,601
Number of cardiology-specific QPP measures: 20

Orthopedics Practices
Estimated average payment adjustment for a 6-clinician orthopedics practice in 2019 alone: $34,603
Number of orthopedics-specific QPP measures: 21

Radiology Practices
Estimated average payment adjustment for a 6-clinician radiology practice in 2019 alone: $30,117
Number of radiology-specific QPP measures: 22

Note: The above projections assume the full incentive and penalty will be paid out as outlined in the MACRA law. However, the positive and negative payment adjustments will be scaled so the program is budget neutral. This means that the positive payment adjustments will have to be offset by penalties.

Navigating the Transition to MIPS
As clinicians prepare for reporting under MIPS, establishing specialty-specific expertise on financial, clinical and technical objectives can help practices thrive rather than just survive.

Tips as you for prepare for MIPS:

  • Know your reporting options and pick your path.
  • Choose measures that play to the strengths of your specific specialty practice. Review your current billing codes and Quality and Resource Use Report to help determine these areas.
  • Do a technology asset inventory to make sure you can track the required CQMs.
  • Customize your EHR for track your selected measures or ID an outsource vendor to assist.
  • Work towards minimum reporting requirements to avoid a penalty with a stretch goal to report on the full required measures to maximize positive adjustment earnings potential.

Additional resources:
QPP website
An overview and support documentation is available at the CMS QPP website here.

MIPS EDU Program
A new “Quality Payment Program in 2017: Pick Your Pace Web-Based Training” course with Continuing Education Credit is available through the Learning Management System. Learn more here.

2017 CMS-Approved Qualified Clinical Data Registries
Additional specialty-specific measures are available via approved 2017 QCDRs to meet MIPS reporting requirements. Options for cardiology, radiology and orthopedic practices are included. Learn more here.

About the Author:
Justin Barnes is a nationally recognized business and policy advisor who serves as Chairman Emeritus of the HIMSS EHR Association as well as Co-Chairman of the Accountable Care Community of Practice. As Board Advisor with iHealth, Justin assists providers with optimizing revenue sources and transitioning to value-based payment and care delivery models. Justin has formally addressed Congress and the last three Presidential Administrations on more than twenty occasions on the topics of MACRA, value-based medicine, accountable care, interoperability, consumerism and more. He is also host of the weekly syndicated radio show “This Just In.” Justin can be found on Twitter at @HITAdvisor.

MACRA Video Training – MACRA Monday

Posted on June 19, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

I did a quick search on YouTube for the term MACRA and it found 23,300 search results. It’s not surprising to find so much MACRA content. It seems to me that healthcare has an insatiable appetite for MACRA information.

While it’s great that so many organizations are producing MACRA content, no doubt some of it is not all that valuable and a bunch of it isn’t accurate. Case in point, the first video returned in the YouTube search for MACRA was a video from eClinicalWorks (eCW). Is there anyone that would want eCW to train them on government regulations after the recent eCW settlement that revolved around their decision to not properly certify their EHR and the meaningful use program? Maybe all the information is accurate, but that’s not where I’d go to for my source of MACRA information.

If you wanted a really brief, high level overview of MACRA, I found this 2 minute cartoon video from MediSync to be a nice intro to the intent of MACRA:

If you want a much more in depth look into MACRA’s MIPS program, you’ll want to check out Answers Media’s 25 videos in their The ABCs of MIPS series:

We all know that the government MACRA website is the first place to go for really high quality MACRA information. Do you have another go to source for your MACRA information that we should know about? Let us know in the comments.