Looking ahead at MACRA/MIPS reporting for physicians

More than 800,000 physician practices got a temporary pass on MACRA compliance from the Centers for Medicare & Medicaid Services (CMS) in May. But practitioners shouldn’t breathe easy just yet.

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The break is only for certain providers and it only applies for 2017, which was slated to be a transition year anyway. Physicians who want to avoid future penalties should start preparing now to comply with MACRA and MIPS reporting requirements in 2018 and beyond.

Understand 2017 exemptions

To aid in the transition, CMS had previously announced reduced reporting requirements in 2017 for physicians and healthcare organizations participating in the Merit-based Incentive Payment System (MIPS). Those who fail to collect and report a minimum amount of performance data this year could face a 4% negative payment adjustment on reimbursements in 2019 - with that penalty amount set to increase in future years.

Under the latest exemptions, physicians with $30,000 or less in Medicare charges and 100 or fewer unique Medicare patients per year, as well as those who are new to Medicare in 2017, will not be evaluated under MIPS this year, and should have received a letter from CMS stating such. If you are now exempt, count yourself lucky.

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​However, that still leaves close to 419,000 clinicians who are supposed to submit MIPS data for 2017. Those eligible providers are not just physicians-also included are some nurse practitioners, physician assistants, clinical nurse specialists and certified registered nurse anesthetists.

Understand MACRA reporting options

Understanding the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is not complicated. It was designed to streamline value-based programs, including Meaningful Use, Physician Quality Reporting System and Value Modifier.  

MACRA outlined two different tracks for participation: the Merit-based Incentive Payment System (MIPS) and the advanced Alternative Payment Model (APM). Most physician practices are expected to use MIPS to comply.

Next: Avoiding negative Medicare payment adjustments

To avoid negative Medicare payment adjustments under MIPS, non-exempt clinicians need to choose one of the following reporting options for 2017:

·       Full-year reporting: If you report all of the required measures for a minimum of a continuous 90-day period, you may be eligible for a positive payment adjustment, depending on your performance results.

·       Partial-year reporting: If you submit performance data on one quality measure, more than one improvement activity or more than the required measures in the advancing care information category for a minimum of a continuous 90-day period, you may have a neutral adjustment or earn a positive payment adjustment-depending on your results.

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·       Minimum reporting: If you report a minimum amount of data for 2017 (e.g., one quality measure, one activity in the improvement activities category), you can avoid a negative payment adjustment, but you will not be eligible for a performance bonus.

In addition, if you will be reporting this year, you need to decide if you will be reporting as an individual or as a group. For more information, visit the Quality Payment Program website.

Refine documentation management process

Whether or not your practice is choosing to report this year, you still need to get your data in order so you will be prepared to meet future compliance requirements. If you don’t already have a proactive documentation management process in place, you should consider establishing one now.

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Having accurate performance data is key to meeting the reporting requirements for MACRA. The quality of your electronic health records (EHR) and practice management (PM) systems as well as the knowledge of your staff in using those systems will affect your ability to report performance data accurately and timely.

If your systems are not working for your practice in the way that you had envisioned, assess whether it is a system problem or a training problem. Most physician practices are underutilizing their EHR system and therefore not maximizing the value of their technology investment.

Next: Mind the timeline

Physicians, clinical staff and administrative staff should receive formal training on the capabilities of the EHR system. Take the time now to contact your vendor and schedule any training that you need to prepare for future reporting requirements.

If you determine that your current system may no longer be a good fit or offer the full capabilities you desire, compare the options on the market against your practice’s needs, and engage a qualified healthcare consultant to assist with the selection process, if needed. 

Mind the timeline

Under the MACRA final rule issued in October 2016, providers could have started collecting performance data as early as January 1, 2017. However, non-exempt providers have until the start of the fourth quarter of 2017 (October 2) to begin collecting data. The more data you report, the higher your chances of qualifying for a positive adjustment.

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March 31, 2018, is the deadline for non-exempt physician practices to submit 2017 performance data to the Centers for Medicare & Medicaid Services, regardless of which reporting option you choose.

CMS is making it relatively easy for healthcare providers to meet the initial reporting requirements and avoid a negative payment adjustment in 2019-as long as you don’t wait too long to act. Start planning now to collect the performance data you need and to develop a MACRA reporting plan that works best for your organization.

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Kevin N. Fine, MHA, is a director of healthcare advisory services in the Miami office of Kaufman Rossin, one of the Top 100 CPA and advisory firms in the U.S.  He can be reached at kfine@kaufmanrossin.com.