Accommodations for small practices in new Medicare pay system
The Medicare Quality Payment Program (QPP), created by the Medicare Access and CHIP Reauthorization Act (MACRA), holds several provisions based on physician recommendations that are intended to bring much needed aid to small and rural practices during the transition that begins Jan. 1.
Small and rural practices have voiced strong concern regarding the transition to the QPP, claiming that they are at a disadvantage under the Centers for Medicare and Medicaid Services’ (CMS) new Medicare payment system. After a review of the MACRA final rule, which details the QPP’s implementation, it appears CMS has made several changes to shore up physicians in those practice types.
A more reasonable low-volume threshold
The proposed rule set the threshold for exemption from QPP participation for physicians who see less than $10,000 in Medicare payments and fewer than 100 Medicare patients per year. Based on physician organization recommendations, in the final rule CMS raised the payment threshold to less than $30,000 in Medicare payments or (key change) fewer than 100 Medicare patients.
Eligibility for low-volume exemption will be calculated by CMS based on historical data from September 2015 through August 2016. Physicians who qualify should be notified in December. If physicians are eligible for exemption, they may still volunteer to report and CMS will provide feedback, but those physicians will not be eligible for a bonus or penalty.
Easing requirements for practice improvement
Under the Improvement Activities category of the Merit-based Incentive Payment System (MIPS), larger practices must report two high-weighted activities (20 points each) and four medium-weighted activities (10 points each) or a combination that reaches 40 points. Accommodating small practices, CMS changed the final rule to ease the reporting burden. Small practices will only need to report one high-weighted activity and two medium-weighted activities.
But there is another option. If physicians from small or rural practices take part in certain quality activities in rural health clinics, Indian Health Services or Federal Qualified Health Centers, that participation will be sufficient for a full Improvement Activities category score.
Test the QPP
Within the “pick your pace” options provided by CMS is an opportunity to test the program, which requires practices to report any data at any point in 2017, report on one quality measure, one improvement activity or the required Advancing Care Information measures. There is no minimum reporting period for this option and participation alone guarantees that a practice will not receive a penalty for the first year of the transition.
Grants totaling $100 million per year will be awarded to quality improvement organizations, regional health cooperatives and other entities to provide technical assistance to small practices to help them participate successfully in the MIPS.
Study up on QPP transition
The first performance period for the new Medicare payment system begins Jan. 1. It is critical that physicians learn as much as they can before that start date. The AMA’s Understanding Medicare Reform collection of educational materials, resources and tools will be continually updated as the AMA learns more about the transition. CMS resources are also included on the website.
The AMA will be hosting two webinars on the QPP: Nov. 21, 7 p.m. EDT and Dec. 6, 8 p.m. EDT. Regional meetings will be held Dec. 1 in Atlanta and Dec. 10 in San Francisco. The regional meetings can be attended in person or online.