“Don’t write off 2017 yet,” says Anders Gilberg, MGA, senior vice president of government affairs for the Medical Group Management Association. “The reporting periods are 90 days and you can still be eligible for the upside bonuses, even if you haven’t started. It’s good to report a few measures to protect yourself now while you continue to learn.”
Protection comes in the form of avoiding a 4% reduction in 2019 Medicare payments for not reporting anything under MACRA in 2017. “The worst thing you can do is take the 4% penalty,” says Gilberg. “It’s too easy to avoid. It would be a shame for physicians to not participate in the context of, ‘it’s too much for me.’”
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To avoid the penalty, physicians need to report only one quality measure or improvement activity, and can start collecting data as late as October, with data submission due March 2018.
Gilberg suggests practices look at the list of measures on the CMS website and search for things the practice is already doing. One possibility might be extended office hours. “Many practices have extended hours because of competition from urgent care centers and many primary care physicians have Saturday hours,” says Gilberg. “These are the types of things that are relatively easy to do, that you may already be doing and will help you be successful in avoiding a penalty.”
There are other easy wins, says Randy Buchnowski, MHA, FACHE, network executive for Halley Consulting Group, a practice consulting firm. He says that the clinical improvement activities category is a “slam dunk,” with 92 options to choose from. For example, if a physician provides timely notification of test results to patients—with the definition of “timely” left up to the physician—that’s a measure that can be attested to and is enough to avoid the 4% penalty.
Doctors can also report as a group, which may be less of a burden, because if one member reports, the entire group gets credit. Everyone in the group will receive the same score, so make sure performance measures are the best the group can deliver, Buchnowski says.
Another place to look for easy wins under MIPS is what a practice is already doing for Medicare quality and value reporting, says Buchnowski. Three of the four categories that make up MIPS—quality, advancing care information and cost—replace physician quality reporting system (PQRS), meaningful use and value-based modifier respectively, and there are a lot of similarities in reporting options.
“These are things that are probably already being done, so let’s not reinvent the wheel,” he adds. “Whatever you do, make sure it works for you in meeting the standards and that it adds real value to patients.”
For Joseph, chronic care management plays a big role in caring for patients and meeting the MIPS requirements. “Between annual wellness visits and chronic care management visits, you can meet two-thirds of MIPS metrics if you can get patients in for those,” says Joseph. Because she is reporting data to MIPS, Joseph will avoid the penalty and be eligible for a payment bonus, depending on how she performs relative to other practices.
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And MIPS isn’t a death knell for independent practices. There are ways to comply while retaining independence: Joseph is using her physician-led ACO to unite practices to work through the challenges as a group; Schlecht is participating in CPC+ to comply. Familiarity with legacy programs like PQRS will make it easier for smaller practices to understand and comply with MIPS.
“I don’t think MIPS will force an independent practice to join a larger health system,” says Buchnowski. “There may be other forces, like access to a better [electronic health record (EHR)] that a small practice can’t afford, but I don’t see anything in MIPS that will force a provider to become part of a larger system.”