The clock is ticking loudly for physicians who want to participate in Medicare’s new value-based payment system.
To earn a small positive Medicare payment adjustment, doctors and practices need to start collecting data Oct. 2 to fully participate in the Merit-based Incentive Payment System (MIPS)—one of the two tracks authorized under the Medicare Access and CHIP Reauthorization Act (MACRA).
With the deadline only 12 days away, it’s scary that many physicians and health systems are still unfamiliar with MACRA requirements. But David O. Barbe, M.D., president of the American Medical Association, the country’s largest physician organization, says he thinks most physicians will be able to comply with the minimum MIPS requirements and at least avoid a payment penalty.
“Above all, we don’t want to see any physician penalized,” Barbe said in an interview with FierceHealthcare earlier this week.
The AMA’s own surveys of doctors revealed a level of awareness about MACRA and confidence in their ability to participate that was fairly low, he says.
A survey released in late June, for example, found that among doctors in decision-making roles, fewer than one in four said they were well prepared to meet quality reporting requirements in 2017.
That looming deadline
Physicians are now in the first year of MACRA, a transition year that allows for a “pick-your-pace” option to help ease them into the new payment system and avoid penalties. The AMA predicts most physicians will be able to meet the basic standard of ‘one patient, one measure’ to avoid a downward payment adjustment or penalty in 2019 for failure to report this year, Barbe says.
But for those who want to qualify for a small positive payment adjustment, time is running out since starting Oct. 2, physicians must begin collecting performance data. MIPS payment adjustments begin in 2019, based on performance in 2017.
Starting Oct. 2 gives doctors who want to fully participate in MIPS a full 90 days' reporting period before the end of the year. The reporting year ends Dec. 31 and doctors can start submitting data on Jan. 1.
But the government has made it even easier for doctors to avoid a payment penalty based on 2017 reporting, allowing them to pick one measure for one patient. So, a doctor, for instance, can report on a measure for ischemic vascular disease for a patient seen for an office visit. The doctor can report one code on one claim that indicates, for example, an unstable angina diagnosis, as indicated in an AMA reporting example. That’s work that can be done quite quickly by a practice team.
Overcoming the time barrier
The AMA and other organizations had lobbied the Centers for Medicare & Medicaid Services (CMS) to make changes to MACRA to make it easier for physicians to participate and won significant concessions, Barbe says. Those included provisions to exempt doctors with a low-volume threshold of Medicare patients and the flexibility that gives them a little breathing room in the first year.
“Physicians want to move programs like these forward,” Barbe says, as the country shifts to value-based care.
The June survey by the AMA found that more than two-thirds of physicians cited time as a significant barrier to meeting MIPS reporting requirements. The AMA encourages all physicians to avoid a payment penalty and like other organizations has designed tools to help, which Barbe says he advises doctors to check out. They include a customizable MIPS action plan and a short video that focuses on “One patient, one measure, no penalty” and how to avoid a negative 4% payment adjustment by reporting one measure via CMS’ claim form.
“I’ve been saying, you can run but you can’t hide. These programs are with us,” Barbe says. Physicians must prepare to move quickly to participate.
Possible changes ahead
The AMA will continue to lobby to make MACRA and MIPS as flexible as possible for doctors, Barbe says.
CMS released a final rule in June that eases some of the reporting requirements under MACRA for smaller practices in 2018, the second year of the program. Some of those proposed requirement changes are because doctors have struggled to prepare for the new MACRA requirements.
The AMA and other physician submitted comments to CMS last month on the proposed rule and are now waiting for the agency to issue a final rule. The AMA called on CMS to make the program “more understandable and less burdensome” and urged it to maintain a slow pace.
CMS, for instance, would increase the MIPS' low-volume threshold in 2018, thereby exempting more than 585,000 eligible clinicians from the program and its reporting requirements. CMS will increase the threshold to exclude clinicians or groups from those with $30,000 to $90,000 in Part B charges or fewer than 100 to 200 Part B beneficiaries.
The AMA supports that change as it is difficult for physicians with a low threshold to make business sense of the program, Barbe says. For instance, a physician with $100,000 in Medicare charges would receive a maximum of a 5% increase in payments, which amounts to only $5,000. It’s likely the physician will spend more than that to participate in MIPs, he adds.
On the flipside, as the rule is proposed, physicians and practices will be excluded even if they want to participate. The AMA would like them to be able to opt-in if they are ready to participate in future years and have the opportunity to earn an incentive payment, Barbe says.
The AMA also wants to see changes to allow more practices to qualify under the second track of MACRA—advanced Alternative Payment Models (APMs), which offers the greatest potential upside for practices long-term, he says. “The reason most physicians are reporting under MIPS is that the requirements are so narrow for APMs that they are excluded.”
The AMA plans to work hard with CMS to change the restrictions so that more types of practices can participate.
While the AMA applauded CMS for its decision to allow for another transition year for MIPS in 2018. Barbe is worried about the future. “Even after 2018, the legislation calls for full implementation for the 2019 performance year,” he says, which may pose a challenge to physicians and practices.