Medicare Compliance & Reimbursement

Oct. 2, 2017 is the deadline to start sending your QPP practice measures.

If Medicare reimbursement is the base of your fiscal livelihood, it’s time to pay the fiddler. MACRA’s Quality Payment Program intertwines the pillars of qualitycare at value prices — but in order to get paid for this transition year 2017’s rendered services, your practice must begin the process of reporting its data ASAP.

Deadlines and dates: If you’ve met MACRA’s QPP low-volume threshold for “transition year 2017” under the Merit-Based Incentive Payment System (MIPS) or are part of an Advanced Alternative Payment Model (APM), the Oct. 2, 2017 deadline is fast approaching to begin submitting your practice data and avoid the 4 percent penalty in 2019. You may report your measures for 2017 through March 31, 2018 with the expected first-payment date on Jan. 1, 2019.

Threshold review 2017: If you are a Medicare Part B physician, physician assistant, nurse practitioner, clinical nurse specialist, or certified registered nurse anesthetist and bill at least $30,000 to Medicare and see 100 Part B beneficiaries annually, plan on sending your details under MIPS. (See Medicare Compliance and Reimbursement, Vol. 43, No. 13.)

However, remember that if you don’t meet the requirements to report, you are excluded from the program and off the hook to report any measures under the four MIPS categories for 2017. “Currently, if a clinician or group does not meet both the Medicare revenue and number of Medicare patients thresholds, the clinician or group is excluded from MIPS and does not have the option to participate,” reminds attorney Benjamin Fee, Esq. of Dorsey and Whitney LLP in the Des Moines, Iowa office.

Know the 4 MIPS Categories and Their Requirements

MIPS, which is the basic path for eligible Part B clinicians and the expected routemost ECs will take for the transition year 2017, incentivizes the offering and endorsement of quality, value-based care and practice initiatives that support it. This pathway focuses on four categories: Cost, Clinical Practice Improvement Activities (CPIA), Quality, and Advancing Care Information (ACI). Your pay is based on your performance in these sections and adjusted accordingly, the MIPS overview fact sheet suggests. “You earn a payment adjustment based on evidence-based and practice-specific quality data,” says CMS. And “you show you provided high quality, efficient care supported by technology by sending in information in the categories.”

Quality: The Quality component replaces the Physician Quality Reporting System (PQRS) for ECs under MIPS and accounts for 60 percent of the composite score needed to reach the magic 100 percent and get a positive pay increase. To stay status quo in 2017, you must do at the very least the following:

• Choose defined measures that match your practice from the options.
• Submit at least 6 Quality measures from the list with 1 outcome measure.
• Ensure the data covers a minimum of 90 days of care and initiative.
• Find 2017 Quality-measures options at: https://qpp.cms.gov/mips/quality-measures.

Remember registered CMS Web-Interface groups must report 15 quality measures instead of 6 through the Web Interface portal. (See Medicare Compliance and Reimbursement, Vol. 43, No. 7.)

Improvement Activities: CPIAs are new to Medicare, and “clinicians are rewarded for care focused on care coordination, beneficiary engagement, and patient safety,” the CMS guidance says. Consider these entry-level requirements that equal 15 percent of the total overall MIPS score to avoid a payment decrease:

• “Attest” at least 4 improvement activities.
• Cover the 90-day minimum for reporting.
• Report only 2 measures if you are registered as a rural provider or serve an underserved population in a practice with less than 15 clinicians.
• Check out the CPIA 2017 activities at: https://qpp.cms.gov/mips/improvement-activities.

“In designing the inventory, we at CMS tried to provide as much flexibility as possible for clinicians,” said Angela Foster, CMS health insurance specialist in the electronic clinical measures division in a webinar on CPIAs. She adds, “We recognize this is a new reporting category. We want clinicians to have the freedom to choose the best activities for their practices.”

Advancing Care Information: For MIPS and Advanced APM providers, ACI ousts Meaningful Use as the required technical component for Medicare reimbursement and covers 25 percent of the MIPS composite. By far the most complicated and intricate of the categories, there are two options for attestation in 2017 to avoid financial censure. Here’s a checklist of the transition year 2017 requirements to keep your practice in the clear:

1. Option 1 proposes that you can submit “ACI Objectives and Measures” if you have either Certified EHR Technology (CEHRT) for 2015 or a combination of CEHRT in the 2014 and 2015 editions. There are 15 measures under this grouping.

2. Option 2 allows you to report “2017 ACI Transition Objectives and Measures” if your CEHRT is part of the 2014, 2015, or 2014 and 2015 editions. There are 11 measures in this set.

This is what your ACI data must include, according to the QPP fact sheet:

• Show that you’ve done a security risk analysis.
• Offer e-Prescribing.
• Provide patient access.
• Promote patient engagement with a summary of care.
• Detail either the request or acceptance of summary of care.
• Report at least 9 measures over a 90-day period of care.

For bonus ACI points and higher payout:

• Include public health initiatives.
• Add data about clinical data registry reporting.
• Utilize CEHRT in the CPIA category.

Find the ACI-measure options at: https://qpp.cms.gov/mips/advancing-care-information.

Cost: The Cost section is not going to be measured for the transition year in 2017 and adds no value to the composite percentage. But in its QPP proposed rule out this past summer, CMS suggests that for Year 2, Cost may account for 10 percent of the MIPS composite and be part of the 2020 payment year. See the QPP Year 2 overview at: https://qpp.cms.gov/docs/QPP_Proposed_Rule_for_QPP_Year_2.pdf.

Note the 2017 Pathways to MIPS Success

MIPS is not all or nothing, especially in 2017 when CMS actually makes it easy to avoid the penalty. The MIPS program comes with a “pick your pace” option that allows you to start your reporting as small or as big as you’re ready to go. Here are the participation categories and the rewards or penalties for each:

• Non-participation: If you are eligible for MIPS and do nothing in 2017, you can expect a negative 4 percent adjustment to payment in 2019.
• Test: If you just try out MIPS — say one quality measure for one patient, or one improvement activity — you’ll avoid the 4 percent penalty. At the very least, this keeps your practice up to speed.
• Partial year: For submitting data for 90 days in 2017, you may earn a small positive payment adjustment.
• Full year: You can earn a moderate payment increase for a full year of reporting data.

Look ahead: “MIPS, and the Quality Payment Program as a whole, are just the latest efforts by the federal government to tie Medicare payments to what CMS views as value and quality,” cautions Fee. “Providers should anticipate that commercial payers will look to the Quality Payment Program as a model that they may be able to follow for paying their networks of providers in the future.”