Podiatry Coding & Billing Alert

These tips will help you easily maximize your MIPS potential in its first year.

MIPS is, in the words of APMA conference presenter Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, “nothing major, only the biggest change in Medicare since inception.” In our last issue, we detailed the potential bonuses and penalties for your podiatry practice in the long run, but here we’ll discuss what you can do in 2017 to begin meeting the standards.

To Participate, or Not to Participate, That is … a Really Good Question

2017 is the trial year for MIPS, and many podiatrists are on the fence about participating in the program. A recent Podiatry Management poll shows that the community is fairly divided, when answering “Do you plan to participate in MACRA/MIPS this year?”

• 21 percent said, “Yes, I will submit the minimum measures required to avoid a penalty.”
• 23 percent said, “Yes, I will submit more than the minimum measures to receive a potential bonus.”
• 39 percent said, “No, I will not participate.”
• 17 percent said, “I do not know enough about it to decide.”

“A lot of people decided to forego efforts in Meaningful Use, because no one is getting to Stage 3,” said Dr. Mark Dollard, DPM, DABPS, FACFAS of Loudoun Foot and Ankle in Sterling, VA. Why? Getting to MU Stage 3 is practically impossible because EHRs aren’t yet truly interoperable and they don’t communicate, he explains. “People have soured on these programs because they aren’t receiving the incentives initially promised to them for their efforts.”

MIPS may be a hassle, but it’s inevitable. It will take an act of Congress (literally) to change and you’re required to participate if you want to maintain optimal levels of Medicare reimbursement.

Important: MIPS is independent of the Affordable Care Act, and so any upheaval from the ACA’s potential repeal will not affect it.

Fortunately, while you’re weighing pros and cons during 2017, you can easily meet the threshold.

And you may be excluded from the participation requirement if:

• You have Medicare billing charges less than or equal to $30,000 or provide care to 100 or fewer Part B enrolled Medicare beneficiaries in one of the two determination periods 

          o 9/1/2015 to 8/31/2016
          o 9/1/2016 to 8/31/2017

• You are a newly Medicare eligible clinician. This includes individual physicians in your practice.
• You are a qualified APM participant

Uncover Minimum Thresholds for 2017

CMS ranks your MIPS performance from 0 to 100. The Performance Threshold is set at 3 and the Exceptional Performance Threshold at 70. This means that any clinician with a score of at least 3 will avoid a negative adjustment, while those scoring 70 or higher will be eligible for an Exceptional Performance Adjustment from the $500 million pool. The range of penalties and bonuses in the years are:

2019: +4 percent to -4 percent, based on your 2017 score
2020: +5 percent to -5 percent, based on your 2018 score
2021: +7 percent to -7 percent, based on your 2019 score
2022: +9 percent to -9 percent, based on your 2020 score

Here are the factors you need to focus on in 2017. Resource Use (or cost) will be 10 percent of the score’s weight in 2018 and moving forward, but the final rule removed it from 2017. To avoid the penalty, you can simply report one quality measure, one clinical practice activity, or report the five ACI measures.

Quality Replaces PQRS, Will be 60 Percent of the 2017 Score’s Weight

To meet the full requirement for the maximum 60, you must report six measures, including a cross-cutting measure. One of those must be an outcome measure if possible, which for podiatry would be the A1c measure.

Take note that the measures must all be reported through the same mechanism, whether it’s registry, EHR, or claims reporting. Here are some to focus on:

Claims Reporting mechanism:

• Documentation of current medications in the medical record
• Diabetes: Hemoglobin A1c (HbA1c) Poor Control – Intermediate Outcome
• Pain assessment and follow-up
• Pneumococcal vaccination status for older adults
• BMI screening and follow-up plan
• Influenza immunization
• Screening for high blood pressure and follow-up
• Tobacco screening and cessation intervention

Registry Reporting mechanism:

• Diabetes: Hemoglobin A1c (HbA1c) Poor Control – Intermediate Outcome
• Diabetes: Medical attention for nephropathy
• Diabetic foot and ankle care, peripheral neuropathy – neurologic exam
• Diabetic foot and ankle care, ulcer prevention – examination of footwear
• Documentation of current meds in the medical record
• Immunizations for adolescents
• BMI screening and follow-up plan

EHR Reporting mechanism:

• Diabetes: Hemoglobin A1c (HbA1c) Poor Control – Intermediate Outcome
• Diabetes: foot exam
• Diabetes: medical attention for nephropathy
• Documentation of current medications in the medical record
• Influenza immunization
• Screening for high blood pressure and follow-up
• Tobacco screening and cessation intervention
• BMI screening and follow-up plan

Advancing Care Information Replaces Meaningful Use, Will be 25 Percent of 2017’s Score

The emphasis for ACI is on interoperability and information exchange, major criticisms of MU. You will need to report on five measures for the 90-day period to avoid a penalty, but can report up to nine for extra credit. Here are the five to focus on to avoid the penalty:

• Security Risk Analysis
• e-Prescribing
• Provide patient access
• Send summary of care
• Request/accept summary of care

Clinical Practice Improvement Activities Will be 15 Percent

CPIA focus on patient engagement, care coordination, and patient safety. For the full 15 points, you must engage in four activities. The bright side is that there are 90 to choose from. You can report on just one of these to avoid the penalty in 2019. Here are examples of easy ones to implement:

• Register in your state’s prescription drug monitoring program
• Develop a program to send reports back to referring physicians
• Consult the prescription drug monitoring program
• Assess patient experience of care through surveys, advisory councils and/or other mechanisms
• Engagement of patients, family and caregivers in developing a plan of care
• Implementation of condition-specific chronic disease self-management support programs

How You Participate is Up to You

To avoid the penalty, you can simply report one quality measure, or one clinical practice activity, or report the five ACI measures.

You can participate for part of the calendar year to avoid a negative payment adjustment and possibly qualify for a small positive payment adjustment. You could potentially earn a full positive adjustment from just those 90 days.

• Report for a minimum of 90 consecutive days
• Report more than one quality measure or more than one clinical practice improvement activity, or more than 5 measures of ACI

For full participation that can max your score out at 100, you’ll need to report the following for 90 days to one year:

• Six Quality Measures
• Two to four CPIA
• Five ACI Measures