At the end of June, the Centers for Medicare and Medicaid Services (CMS) released the proposed final rule for year two of the Quality Payment Program, established under MACRA. Do you know how the proposed changes impact your urgent care practice?
MACRA is legislation passed in 2015; it stands for the Medicare Access and CHIP Reauthorization Act. It repeals the Medicare Sustainable Growth Rate (SGR) formula that paid clinicians based on volume of services rather than quality or value. MACRA replaces SGR with the Quality Payment Program (QPP), which is designed to reward the delivery of high quality patient care and consolidates various quality reporting programs.
The Quality Payment Program is tied to Medicare Part B and is facilitated by the Centers for Medicare and Medicaid Services (CMS). QPP was established under MACRA, and it has two Medicare Part B payment tracks:
The final rule for year two of the QPP is expected to be released November 1, 2017, and the timeline is quite aggressive:
The MIPS track is the most relevant to urgent care practices. Payment adjustments are a percentage of a provider’s Medicare Part B billings and are performance-based, with scoring for the 2017 performance year conducted using four weighted categories:
Payment adjustments for 2017 participation will be made in 2019.
Eligible clinicians include any physician, nurse practitioner, physician assistant or clinical nurse specialist who participates in and bills Medicare Part B. You are not eligible if:
If you’re not sure whether you’re eligible, you can enter your NPI into CMS’ MIPS Participation Status tool to check your eligibility. Eligible clinicians can participate individually under the NPI and TIN to which they reassign benefits or as a group with two or more NPIs who reassign to a single TIN.
CMS created a “Pick Your Pace” approach for year one participation:
The exact amount of the potential and enhanced bonuses will be determined by your score compared to other eligible clinicians’ scores.
Although Meaningful Use wasn’t mentioned in the MIPS performance categories, it hasn’t gone away; it’s been integrated into the Advancing Care Information (ACI) performance category. At this point, eligible clinicians can use EHR technology certified for either the 2014 or 2015 editions to report the 2017 objectives and measures; however, you’ll report different measures depending on your EHR’s certification year.
This is an extremely high-level overview of the QPP, and there are more changes coming in November. If you’re not sure where to go from here, follow this checklist to get you started:
It’s vital you check your eligibility and form a plan for how your practice will participate in the QPP because this will help you avoid a negative payment adjustment. However, be flexible with your plan because changes to the QPP might come in November if CMS implements any of the feedback it receives during the commenting period. Staying informed and agile will help you navigate this new legislation.