MIPS Preparedness for Small Medical Practices

Posted on 15 Jun, 2017 |comments_icon 5|By Jeff G Lawson

Practices with 15 or fewer clinicians and practices in rural and health professional shortage areas are a crucial part of the healthcare system.

The Quality Payment Program provides options designed to make it easier for you to report on your performance and qualify for incentives. Physicians in small practices who report their performance can do just as well as mid-sized or larger practices.

CMS expects the number and percentage of small practices participating in the Quality Payment Program to increase and exceed participation in legacy programs (for example, PQRS) because of the reduced reporting burden, increasing usability of technology, and stepped-up technical assistance. There are a number of other flexibilities in the final rule to help small practices.

Small practices will be able to successfully participate in the Quality Payment Program with considerations that strive to:

  • Reduce the time and cost to participate
  • Provide an on-ramp to participating through Pick Your Pace (see below)
  • Increase the opportunities to participate in Advanced APMs
  • Include a practice-based option for participation in Advanced APMs as an alternative to total cost-based
  • Conduct technical support and outreach to small practices through the forthcoming QPP Small, Rural and Underserved Support (QPP-SURS) as well as through the Transforming Clinical Practice Initiative.

MACRA provides $20 million each year for five years to fund these training and education efforts for Medicare clinicians in individual or small group practices of 15 clinicians or fewer and those working in underserved areas.

Beginning December 2016, local, experienced organizations will use this funding to help small practices select appropriate quality measures and health IT to support their unique needs, train clinicians about the new improvement activities and assist practices in evaluating their options for joining an Advanced APM.

Providing these tools to help physicians and other clinicians in small practices and practices in underserved areas navigate new programs is key to making sure they are able to focus on what is most important: the needs of their patients.

Small, Rural and Health Professional Shortage Areas (HPSAs) Exceptions include an:

  • Established low-volume threshold Less than or equal to $30,000 in Medicare Part B allowed charges OR Less than or equal to 100 Medicare patients
  • Reduced requirements for Improvement Activities performance category One high-weighted activity OR Two medium-weighted activities
  • Increased ability for clinicians practicing at Critical Access Hospitals (CAHs), Rural Health Clinics (RHCs), and Federally Qualified Health Centers (FQHCs) to qualify as a Qualifying APM Participant (QP).

Pick Your Pace

Regardless of your size or location, if you choose the Merit-based Incentive Payment System (MIPS) path of the Quality Payment Program, you have options. You can choose to:

  1. If you choose not to participate

If you chose not to participate in the Quality Payment Program for the Transition Year and don’t send in any 2017 data, then you will receive a negative 4% payment adjustment.

  1. If you submit just one data point

If you submit a minimum amount of 2017 data to Medicare, (for example, one quality measure or one improvement activity for any point in 2017), you can avoid a downward payment adjustment and experience a neutral or small payment adjustment.

  1. If you submit 90 days of data

If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.

This means if you were not ready on January 1, you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you’ll need to send in your performance data by March 31, 2018. Remember, you can send information for 90 days — or longer, up to a year if you chose to do so.

  1. If you submit a full year

If you submit a full year of 2017 data to Medicare, starting January 1, 2017, you may earn a modest positive payment adjustment.

The best way to earn the largest positive adjustment is to participate fully in the program by submitting information in all the MIPS performance categories.

  1. If you choose to participate in an advanced APM

Some practices may choose to participate in an Advanced Alternative Payment Model or Advanced APM in 2017

*Key Takeaway: Positive adjustments are based on the performance data on the performance information submitted, not the amount of information or length of time submitted.

To learn more about MIPS participation, incentives, and scoring—and to stay on track for optimum reimbursement with strategies to avoid payment cuts in the coming years—pick up your copy of Guidebook to Medicare Access and CHIP Reauthorization Act of 2015.


Jeff G Lawson

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