CMS seems to have done a complete turn-around since its 2016 release of mandating MACRA participation, especially for the Advanced Alternative Payment Models (APMs). As of this year, over 800,000 clinicians are not expected to comply with the MACRA MIPS reporting, which could have potentially saved them million in compliance costs.
Who are exempt, and who are not?
MIPS reporting still has some credence, despite a large percentage of practices being exempt from it. About 418,000 physicians are still required to submit their MPIS data in a timely fashion. This change came into place after the CMS updates the formula to estimate the Medicare revenue of the providers.
The one who is exempted from MIPS reporting are those physicians with a smaller practice, who have less than $30,000 in Medicare charges, and those with less than a hundred unique Medicare patients per year. The agency also seems to have included those who have incorporated a MACRA compliant Advanced Alternative Payment Model, which is another value based reimbursement track that the physicians can opt to choose. Physicians who are new to Medicare this year are also exempt from MIPS reporting, due to obvious reasons.
How is MIPS calculated?
MIPS effectively amalgamates the existing Medicare Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM) under a single payment portal. This payment adjustment is supposed to be applied to the Medicare part B payments in the year 2019. 2017 was supposed to be the start of the two-year precursory period from when the physicians had to incorporate the MIPS into their payment plans.
MIPS outlines four factors that contribute to the annual MIPS score (of 100 points). The relative weight of each of these factors are as follows-
- Quality of health care stands at 60%
- Advancing Care Information (ACI) is at 15%
- Clinical Practice Improvement Activities (CPIA) is at 15%
- Resource Use is at 0% currently but is expected to change from 2018 onwards.
All the above percentage allocations are for the year 2017 only and is expected to change 2018-19 onwards.
This final score thus calculated then determines the MIPS payment adjustment for the successive second calendar year, and each physician’s annual score will be released to the public by the CMS.
The financial impact of MIPS
The physicians participating in the MIPS will have to face two major changes to their financial status. The first one is a small annual inflationary adjustment that is added to the Part B fee schedule, and the second one is the MIPS value-based payment adjustment based on the MIPS 100 point score. The value-based payment might be an incentive or a penalty based on the current MIPS score.
The inflationary adjustment is +0.5% increase for the payment years CY2016 and CY2019. It will then resume in CY2026 and thereafter in the scale of +0.25% annual adjustment. However, the potential of an incentive via MIPS is quite substantial when compared to the inflationary adjustments, thus it evens out year after year.
The Medicare reimbursements for the year 2019 will be based on the performance metrics of CY2017 and CY2018, which will effectively enable the physicians to earn a bonus on their reimbursement in 2019.
At MedConverge, we help our clients to file their MIPS accurately that is in accordance with the current guidelines.
References
- Dickson, V. (2017, May 11). CMS gives 800,000 docs a pass on MACRA requirement. Retrieved May 2017, 2017, from Modern Healthcare: http://www.modernhealthcare.com/article/20170511/NEWS/170519964
- Masterson, L. (2017, May 14). More than 800K physicians get MACRA reporting reprieve for 2017. Retrieved May 21, 2017, from Healthcare DIVE: http://www.healthcaredive.com/news/more-than-800k-physicians-get-macra-reporting-reprieve-for-2017/442652/
- Mulero, A. (2016, October 25). CMS pushes for more MACRA participation with new Advanced APM options. Retrieved May 21, 2017, from Healthcare DIVE: http://www.healthcaredive.com/news/cms-pushes-for-more-macra-participation-with-new-advanced-apm-options/429009/
