2018 MACRA regulations are being released, and we'll be sure to get you prepared for success for the coming year of reporting. In the meantime, you have plenty of time to make sure that you successfully participate in the CMS incentive program this year.
In the webinar, Are You On Track for MIPS Success? our regulatory expert Beth Onofri, walked us through the simple steps providers need to know about MACRA and what they need to do for the remainder of 2017. Below you'll find the SlideShare presentation, the recorded webinar, and the question from our participates that further illuminate the process.
Our webinar participants stayed engaged throughout the presentation and brought up some important questions that will be of interest to healthcare providers. Here are responses from our webinar presenter and head of Kareo Expert Services Beth Onofri:
1. If you have a small practice with a physician and a physician's assistant. Do you submit information per each category for each, or the best scores?
For a physician and physician assistant, you want to report individually. Each individual would report their results in the three categories.
2. Can you participate in MIPS if you do not use an EHR? Is 2015 edition the most recent certification?
You must use a certified EHR to participate in MIPS. The EHR needs certain functionality and the ability to run certain reports. Kareo completed the 2014 certification three years ago, and is currently working on the 2015 certification. And yes, that will be the latest edition. For 2017 reporting, practices can use a 2014 or 2015 certified EHR. For 2018, the EHR must have the 2015 certification.
3. Can Physical therapist, Occupational therapist, home health agencies, or psychologists participate in MIPS?
Physical therapist and occupational therapist have been excluded from the list of eligible participants for 2017 and 2018. There is no mention as to why they are excluded, but they may be eligible in the third year of the program. Home health agencies need to check with CMS on their eligibility of the program. Best advice is to determine who runs the program; eligibility is not about the agency itself, it’s more about the provider. For psychologists, if you do not have an MD degree, you are also exempt this year; social workers or doctorate degrees are not currently eligible for MIPS.
4. You mentioned 30% Medicaid participation threshold for MIPS. I am under the impression it is a 30% Medicare participation threshold. Please confirm Medicaid or Medicare?
The 30% we referred to was for Meaningful Use and that was based on Medicaid patient population. If your practice serves 30% or more patients, you are eligible to participate in the Meaningful Use program. The eligible individuals for MIPS are:
- Physician (e.g., Doctors of Medicine or Osteopathy, Doctors of Dental Surgery or Dental Medicine, Doctors of Podiatric Medicine, Doctors of Optometry, Chiropractors)
- Physician assistant
- Nurse practitioner
- Clinical nurse specialist
- Certified Registered Nurse Anesthetist
Currently there are some exclusions, such as having less than 100 patients or having less than of $30,000 of billing for Medicare patients.
5. What if you are a physician that has no direct contact with patients, such as remote reading of patient data?
For individuals in this situation, we advise you to contact CMS directly. There are some scenarios where a certain category may be excluded for particular groups. For example, hospitalists do not have control over their EHR. So, advancing care is not something they participate in; instead the 25% goes to the quality aspect. There are several nuances to MIPS--for those who are uncertain go to www.qpp.cms.gov. Type in “NPI” and see if it indicates if you are eligible, and if you have any more questions contact the CMS helpline.
6. Does each measure have the same value for my overall score?
Advancing care measure - Under the performance score, there are measures that are weighted at 20 points and others that are 10 points. For the 20 points, you accumulate a range based on how well your practice is doing. You will receive a higher score the higher you participate in it. The base score has equal value (10 points); once you complete items it is simply yes or no. You receive the full value or no points.
Quality measure - There are over 100 pages explaining quality reporting and scoring. Basically, CMS has set a benchmark for each measure, they are hoping to evaluate the measure against that threshold for individuals. It is advised that you to do the best to achieve the highest score possible.
7. How do we send data to CMS at the end of the reporting period? What is the name of the registry that Kareo uses?
For the Quality component you can report via claim submission or through a qualified registry. The qualified registry that Kareo has a relationship with is Covisint. If you are a Kareo user, you will receive $100 discount on their submission fee of $399. If you are part of a professional organization, such as the Comprehensive Joint Replacement, they have a registry themselves and is typically free for participants.
For Advancing Care for small practices, it is advised to use the attestation site on the CMS website, it is still in development. It will be available once reporting is being accepted. You are unable to report until January 2, 2018.
Lastly, for Improvement activities, you can use a use a qualified registry or the CMS attestation website.
8. Is the penalty or increase in pay based on data submitted relevant to the entire fee schedule for Medicare published each year or is it just a onetime penalty per year?
For 2017, if an individual participates, it is a -4% off their reimbursement of 2019. There is a two-year lag time for the penalty and incentive payments. The penalty and potential positive reimbursed increases with each year; this year is -4%, next year -5%, followed by -7%, and then -9%. As you can see, for those not participating it gets worse as the years go on. There is a potential to receive 0% to 4% positive reimbursement—it is based on a comparison of your info to the threshold and everyone else who submitted results as well. You won’t know what you’re getting until later, since it is “graded on a scale.” This is a budget mutual program; they do not spend any more money than the accumulated penalty for other providers. For the over achievers, you have the potential of receiving a bonus up to three times the highest amount. This reporting year is 12% (4% x 3); in the future, they have potential for up to a 27% positive adjustment.
9. I'm part of a group practice, if one of the providers doesn’t do the proper reporting will it affect my reimbursement?
If you are reporting as individuals, there will be no effect on your reimbursement. If you are reporting as a group, then the results of all individuals in the group are averaged together and the reimbursements adjustment is applied to all providers.
10. I just checked the QPP website to see if my PA is required to participate in MIPS, it says he is exempt but states that he qualifies if reported as a group. Please advise.
If the PA is in practice with other eligible clinicians and the practice decides to report as a group, then his results would be included in the group numbers. If the providers in the practice are reporting individually, then he does not need to participate.
11. For the base component of Advancing Care, there is a requirement for online Patient Access. Does this component require a certain number or percentage of patients to log on? Many patients I see do not have/use a computer?
The Base Score of Advancing Care requires that each measure is completed for at least one patient.