Podiatry Coding & Billing Alert

In early September, the Centers for Medicare & Medicaid Services (CMS) — under intense pressure from healthcare providers and policymakers — decided to delay the start of MACRA and make the requirements easier for providers to meet.

Wait a minute. What’s a MACRA again?

Don’t worry. We’ll break it down for you. Passed last spring, the Medicare Access and CHIP Reauthorization Act of 2015 will move Medicare reimbursement away from a fee-for-service model and towards a value-based model. MACRA ends the Sustainable Growth rate Formula that was used for years to update Medicare payment rates. That formula is being replaced with MACRA’s Quality Payment Program (QPP) designed to reward Medicare providers for quality care, rather than paying them based on the number of services they provide.

The value-based medicine that MACRA promotes gives payers a way to rein in the high costs of healthcare by implementing variations on the reimbursement model. With MACRA, CMS intends to provide better care to patients, encourage smarter spending, and increase Americans’ health.

If you want to continue receiving reimbursements on the services you provide for your Medicare patients — and if you are eligible to participate in the QPP — you have to use one of the new payment models.

How does it work?

The QPP consists of two tracks for reimbursement from which podiatrists and other providers can choose: the Merit-Based Incentive Payment System (MIPS) or an alternative payment model (APM), such as an accountable care organization, patient-centered medical home, or bundled payments.

How do I know which option is right for my podiatry practice?

Let’s compare each of the payment models under MACRA.

MIPS. MIPS includes elements of the Physician Quality Reporting System, the Value-based Payment Modifier, and the Medicare Electronic Health Record incentive program. Under MIPS, penalties and rewards will be dependent upon a practice’s performance in four areas: Quality, Resource Use, Clinical Practice Improvement, and Meaningful use of EHR. If you go with MIPS, you’ll still be paid for the services you provide, but MIPS will determine whether you receive a plus or minus adjustment (of up to 9 percent) to what you are paid — based on your performance in those areas.

Physicians who receive an extremely high score in those categories are eligible for a 27 percent payment bonus. Rewards and penalties will take effect in 2019, but they’ll be based on the data you reported for 2017. If you have an EHR already or plan to implement one, then MIPS may be the right option for you.

APMs. Providers who go with an alternative payment model under MACRA receive a 5 percent annual bonus payment and do not have to participate in MIPS. Podiatrists considering this model will need to be part of a group that is linked to an ACO, hospital, or large medical group. If you’re not in one of these groups — for reasons including a lack of ACOs in your region or local-level medical politics (specialists like orthopedists want to keep out chiropractors and podiatrists because they want to keep the surgeries — big cash opportunities — for themselves, according to the June/July 2016 issue of Podiatry Management), then you should go with MIPS or a commercial equivalent.

Bottom line? You need to choose your option soon and start preparing to report correctly under that model. While you do have flexibility in when you implement MACRA, your rewards/penalties will be dependent upon your 2017 data, so the earlier in 2017 you start reporting, the better.

How can I prepare?

MACRA may be a disruptive and overwhelming piece of legislation, but it’s coming fast and you cannot afford to bury your head in the sand. Keep reading for our best tips on how to prepare for MACRA so that your practice makes a smooth transition and captures all cash opportunities.

MACRA Prep Tips

1.  Educate yourself and your staff:  Involve your entire podiatry practice in learning about MACRA. Read industry blogs and publications. Use resources from the American Podiatric Medical Association and other podiatry organizations.
2.  Make your coding flawless: Many practices use incorrect or inadequate coding — mostly because of fear of Medicare — which creates big revenue leaks. Hire well-trained coders, send your current staff to coding workshops, or hire a Revenue Cycle vendor trained in MACRA who will handle all of your coding for you.
3.  Invest in equipment: Purchase equipment that allows you to perform lucrative services. According to Podiatry Today, for example, a muscoskeletal ultrasound machine will be well worth the reimbursement you receive from associated procedures. Also, an extremity MRI machine is powerful enough to pass all requirements of insurance companies. And extracorporeal shockwave therapy (ESWT) is a perfect addition to your practice if you see plantar fasciopathy — and while insurance doesn’t typically cover ESWT, patients are usually happy to pay cash for the procedure if it means they can avoid surgery. Adding equipment to your practice not only makes it more convenient for patients to get the care they need, but it also increases the number of high-value services you can offer.
4. Limit the power of your payers: No single payer, whether it’s Medicare or a private company — should take up the majority of your reimbursement situation. Guard against reimbursement swings by making sure that your payers hold 1/3 or less of a share in your practice.
5. Grow your side hustle: Supplement your reimbursement income and keep your practice independent from the Medicare system by offering additional services like Botox injections, orthotics and topical cream sales, physical therapy etc. Consider getting involved in research studies. There is a ton of money designated for foot and ankle research. If you can help organizations get patients who are appropriate for their study, the sponsoring company may pay you $100 or more per patient.

Anything else I need to know?

Yes. After receiving thousands of comments from providers and policymakers about the too-high requirements and too-short deadlines for MACRA, CMS announced that it will allow providers to choose the level and pace at which they comply. Eligible physicians and other clinicians have four options to comply with MACRA:

1. If providers report any data in 2017, they avoid financial penalties
2. Providers are allowed to submit data for a reduced number of days, meaning that their first performance period could begin after the original start date of MACRA, Jan. 1, 2017.
3. If practices are ready to comply with all MACRA requirements at the start of 2017, they can go for it. 
4. Providers can participate in an advanced alternative payment model, like a Medicare Shared Savings ACO. While this added flexibility is helpful for podiatrists and other physicians, you need to take action now on getting your practice up to speed and ready to go live with MACRA in 2017.