3 steps to avoid a penalty under MACRA

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There's still time to report data and avoid a Medicare payment penalty that would hit in 2019.

As 2017 winds to a close, it’s not too late for physicians to avoid a financial penalty for not participating in the new Medicare payment program.

The American Medical Association’s president-elect, Barbara L. McAneny, M.D., outlined several steps physicians can take to still participate under the Merit-based Incentive Payment System (MIPS), one of two available payment tracks under the Medicare Access and CHIP Reauthorization Act (MACRA).

Using steps from the AMA’s MIPS action plan and resources from the Centers for Medicare & Medicaid Services, physicians can avoid a negative 4% Medicare payment adjustment in 2019 with minimum participation: reporting one measure for one patient this year.

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McAneny suggests the following steps:

1. Check CMS’ online MIPS participation status tool to see if you are exempt from the program. To check, enter your 10-digit National Provider Identifier number into CMS’ tool to determine whether you should participate in MIPS. In 2017, CMS exempted physicians with less than $30,000 in Medicare payments or fewer than 100 Medicare patients from MIPS.

(The number of physicians who are exempt will actually increase next year as a new CMS final rule increases the threshold to exempt physicians with less than $90,000 in Medicare payments or fewer than 200 Medicare patients.)

2. Review the available performance categories and decide how you will participate. Under minimum participation, you can submit data for one quality measure, one improvement activity or some of the elements within the advancing care information category, McAneny says. Most physicians will likely choose to report a quality measure, which you can report directly on the claim you submit to Medicare, she adds.

While CMS allowed a “pick your pace” option in 2017, under the final rule for next year it will get tougher for practices. Along with the one-measure minimum, physicians could be eligible for an incentive payment this year by reporting 90 days of quality data. Next year, they will need to report a full year of quality data—a change which disappointed many, including the Medical Group Management Association.

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As a backup, Suzanne Falk, MGMA’s associate director of government affairs, recommends that practices report data on more than one measure, in case there is a problem with the data.

You can use CMS’ Quality Measures Search Tool to select which quality measure to report. McAneny suggests practices use measures that apply to your patients or the procedures you perform most frequently.

3. Determine which reporting mechanism you will use. You can report MIPS’ data through qualified registries, qualified clinical data registries or some electronic health records, she says. But you must collect the data for MIPS performance by Dec. 31, 2017. The submission deadline for 2017 data is Feb. 28, 2018.