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 would be best for you and your patients.
Are you exempt under the MIPS low-volume threshold?
CMS has proposed that ob-gyns who see 100 or fewer Medicare Part B patients and have $10,000 or less in submitted Medicare charges are exempt from reporting in MIPS. ACOG estimates that at least 50 percent of ob-gyns who currently bill Medicare will meet this threshold and be exempt from reporting. We’re working to make this threshold easier for ob-gyns to reach, advocating for 150 patients and $30,000.
In order to evaluate whether or not you may be exempt from MIPS, you should review your 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 submitted charges to Medicare exceeded $10,000 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 National Provider Identification (NPI) number to determine whether you 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 exceed your negative payment adjustment?
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.
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 EHR systems used by practices sharing the same TIN could complicate your reporting.
Other important steps:
- Prepare your practice and make changes now to help you succeed and thrive under MACRA, and most importantly, continue to provide high-quality care to your patients.
- ACOG estimates that up to half of all ob-gyns who bill Medicare will be exempt under the low-volume threshold. Figure out NOW whether you fit into this group.
- Review ACOG’s practice toolkit and checklist to figure out what steps you need to take to get ready. In the coming months, ACOG will release a practice toolkit and practice checklist with additional considerations and steps to take to ensure you’re ready to go on Day 1.
- Learn about the New Payment System. It’s a whole new way of getting paid, moving to the quality of care we provide. There’s a lot to learn, starting now.
- Advocate for Needed Changes. MACRA, like every system, program, and entity we’ve ever come across, is far from perfect. Many changes need to be made to make it work right. Here’s what ACOG is doing.
- ACOG provided extensive comments to the Centers for Medicare and Medicaid Services about how to improve the Quality Payment Program so it works for ob-gyns.
- ACOG is working closely with Members of Congress to ensure that CMS implements the program as Congress intended, to help physicians care for patients.
- ACOG will ask for your help in weighing in with policymakers about how the program affects practicing ob-gyns.
- Work Together. Together, we’ll help each other rise to this new challenge. We’ll all need to embrace this change and work for a positive outcome.