There are a number of considerations you should take into account when determining how the Quality Payment Program (QPP) will impact your practice, and what options will be best for you and your patients.
Are you exempt under the MIPS low-volume threshold?
Individuals and groups that submit $30,000 or less in Medicare Part B charges or see 100 or fewer Medicare patients are exempt from MIPS. CMS will notify you between December 2016 and February 2017 if you are a low-volume provider. If you are notified, you will not need to report during the upcoming performance period as an individual.
However, if you are a member of a group, you will need to determine whether or not your group meets the low-volume threshold.
You should review your group’s patient panel to see whether you saw 100 or fewer Medicare Part B patients in the previous calendar year. (Please note, Medicare Advantage patients are not included in MIPS.) You should also query your electronic health record (EHR) system to determine whether your practice payments from Medicare exceeded $30,000 during the previous calendar year. If you cannot access this information in your EHR, you can also access publically-available Medicare data and search for your Tax Identification Number (TIN) to determine whether your practice may meet the low-volume threshold based on previous years.
Exempt physicians will receive a 0.5 percent payment adjustment to the Physician Fee Schedule in 2019 and no payment adjustment from 2020 to 2025 to the fee schedule. In 2026 and beyond, exempt physicians will see fee increases of 0.25 percent to the Physician Fee Schedule. MIPS reporting is voluntary for exempt physicians, but reporting won’t result in any additional payments.
Will the cost of reporting in MIPS exceed your negative payment adjustment?
If you are not exempt, you should carefully examine how the infrastructure and staff costs required for MIPS reporting compare to your greatest potential payment cut in each performance year:
2019, 4 percent,
2020, 5 percent,
2021, 7 percent,
2022 and beyond, 9 percent.
If you would report as an individual, check your previous year’s Medicare revenue to see how your practice would fare if you didn’t report and received the lowest possible score. If reporting as a group, you’ll need to aggregate the revenue received from Medicare across all reporting providers in the group.
Estimated Burden for Quality Reporting in MACRA Final Rule
In the final rule, the revised estimates for the amount of time required for a physician to report quality measures under MACRA are higher than the proposed rule. CMS explains that the higher cost per physician reflects updated wage estimates, a more accurate average number and expands the type of staff responsible for reporting — the proposed rule had left out LPNs and some administrators. The rule also includes fees associated with reporting registries. CMS added an additional hour burden per physician “to become familiar with quality-measure specifications” in each category after commenters suggested the proposed time estimates were overly conservative. The extra hour only applies to the estimated burden for the initial transition year as CMS expects reporting time will subsequently decrease. (Access the Estimated Burden graph below in PDF format)
*Burden estimate applies to those MIPS-eligible clinicians submitting data through these mechanisms either as individuals or as a group.
Sources: CMS final rule and proposed rule for implementing Quality Payment Program under Medicare Access and CHIP Reauthorization Act of 2015
Should you report as an individual or as a group?
Groups are identified by Tax Identification Number (TIN) and are defined as having two or more eligible clinicians who have reassigned their billing rights to the TIN. Consider whether reporting as a group may limit your ability to report on relevant quality measures if you’re in a multispecialty practice and whether multiple electronic health record (EHR) systems used by practices sharing the same TIN could complicate your reporting.
If you are part of a group with many low-volume Medicare providers, you may want to consider advocating that everyone in your group report as individuals since the same low-volume threshold is applied to both individuals and groups.
You will have to un-assign your billing rights to the TIN if your group opts to report as individuals. You cannot carve out low-volume providers from a group.