Pathology/Lab Coding Alert

Move seamlessly from PQRS to MIPS

As 2017 gets underway, quality reporting is here in a big way that you can’t afford to ignore. Understanding the impact of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is crucial if you want to preserve your Medicare pay.

In fact, “MACRA represents the most significant change to Medicare’s physician payment system in a generation …” said Andrew Gurman, MD, AMA president, in a press release responding to the final rule.

Don’t miss out: “A recent survey performed by The Physicians Foundation found that only 20 percent of physicians are familiar with MACRA,” says Sarah Warden, Esq., of Greenspoon Marder in Ft. Lauderdale, Florida. “That statistic is troubling considering the amount of money at stake.”

Do this: Study the following Q/As to make sure you have the tools you need to maximize your reimbursement — or at least avoid pitfalls that will result in a negative payment adjustment for your pathologists.

Question: How does quality reporting under MACRA relate to earlier programs such as PQRS, EHR, and VM?

Answer: Before MACRA, Medicare paid physicians based on a fee-for-service structure called the Sustainable Growth Rate. However, CMS had instituted several quality reporting initiatives in recent years, such as Physician Quality Reporting System (PQRS), Electronic Health Record (EHR) incentive program called “Meaningful Use,” and Value-Based Payment Modifier (VM).

These began as voluntary programs and varied in payment impact from neutral, to small incentives, to penalties. In fact, eligible clinicians who don’t report to PQRS for 2016 services can expect a 2 percent payment reduction from Medicare Physician Fee Schedule rates in 2018, according to Carol Jones, MSN, CMS Program Analyst, in a Jan. 24 MLN Connects National Provider Call.

Under MACRA, CMS phases out data collection for any of the previous programs for services beginning Jan. 1, 2017 (although data reporting from performance-year 2016 continues into 2017). Instead, you’ll have a new Quality Payment Program (QPP) with two paths: Advanced Alternative Payment Model (APMs) (which most practices won’t qualify for this year), or Merit-Based Incentive Payment System (MIPS).

Important: Eligible clinicians must report data using MIPS in 2017 or face payment penalties in 2019.

MIPS aims to evaluate performance under four categories, three of which parallel the three terminated programs, as follows:

• Quality — primarily replaces PQRS
• Advancing Care Information — primarily replaces Meaningful Use of EHR
• Cost — primarily replaces VM
• Improvement Activities — new quality category for evaluation.

Clinicians will receive a score in each category, which CMS weights according to the relative importance assigned to each, to arrive at a single score between 0 and 100. The category weight may change over time and based on clinician characteristics.

Question: Is participation in MIPS “all or nothing” in terms of getting a payment incentive or penalty?

Answer: No, 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 your pathologist is eligible for MIPS and does 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. This is a no-brainer, people.
• 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.

Question: Who is eligible to participate in QPP to earn incentives and avoid penalties?

Answer: Unlike under PQRS, pathologists associated with independent laboratories may now participate in QPP if they’re otherwise eligible.

Clinicians who meet the “low-volume” threshold don’t need to participate in a QPP. Low volume means seeing 100 or fewer unique Medicare patients a year, or having $30,000 or less in annual Medicare Part B allowed charges. Also, clinicians newly-enrolled in Medicare are exempt in their first year, according to Molly MacHarris, CMS Health Insurance Specialist, in a Jan. 24 MLN Connects National Provider Call.

Non-patient facing: Of particular importance to pathologists is the MIPS exception for “non-patient facing” clinicians. Because pathologists frequently evaluate patient specimens without actually seeing the patient, this exception could mean that you’ll face lower reporting requirements and performance metrics under MIPS. CMS defines a non-patient-facing clinician as an individual who bills 100 or fewer patient-facing encounters a year, or a group with at least 75 percent of eligible providers designated as non-patient-facing clinicians.

Question: What are the reporting requirements for the four MIPS performance categories?

Answer: The reporting requirements are as follows:

Quality — Eligible clinicians need to report six quality measures (compared to nine under PQRS) or a specialty measure set. One of those must be an outcome measure (if available) or a high-priority measure if no outcome measure is available. To meet the measure, clinicians should report on 50 percent of patients in 2017, growing to 60 percent in 2018 and possibly more in later years. Non-patient-facing clinicians should meet the same standard, if possible, or as many as possible. See “Know Which Measures Your Pathologists Can Turn To” on page 21 for a list of pathology measures.

Cost — This category is based on claims, and carries no weight for eligible clinicians in 2017. However, the cost category will increase to 10 percent in 2018 and 30 percent in 2019 and beyond. No weight is given to the cost category for non-patient-facing clinicians.

Advancing Care Information (ACI) — This category will be zero-weighted for non-patient-facing eligible clinicians if no measures are applicable. Otherwise, eligible clinicians need to report on all base-score measures (four in 2017, five in 2018) and up to nine optional measures for a higher score. The reporting period is 90 days for 2017 and 2018, but will increase to the full year. You can read about the ACI measures at https://qpp.cms.gov/measures/aci.

Improvement Activities — Eligible clinicians should report a total of 40 points-worth of improvement activities (such as two-high weighted or four-medium weighted activities). Non-patient-facing clinicians need to perform just two medium-weighted or one high-weighted activity. You can find a list of activities at https://qpp.cms.gov/measures/ia.

You can read more about performance measures at https://qpp.cms.gov/measures/performance.