All too often, doctors of chiropractic come to the office on Monday morning and immediately head into a treatment room to take care of the first patient of the day.
From that point onward, the week seems to fly by and there will usually be little work done on developing the practice. Staying above the waterline can be a challenge for anyone in healthcare these days—and the circumstances regarding the new Medicare Access and CHIP Reauthorization Act (MACRA) will play a dramatic role in how practice is conducted in the future.
Third-party reimbursement is at stake for the doctor of chiropractic, as well as participation in integrated care delivery.
For a practice unwilling to make the necessary changes to implement an EHR system and report on performance categories, the alternative is to either take fewer reimbursements or convert to a strictly cash-based practice. Deciding how you will operate under MACRA is an important business decision.
A practice benchmark
Going cash may seem appealing at first—just saying “the heck with all of these regulatory changes.” But we are in the era of online presence and transparency. Your reputation is at stake, and even today your performance is being publicly displayed by Medicare. This will continue to become more prominent not only with Medicare but with other payers, too.
Do you want your lack of performance with third-party payers to reflect on your reputation as a clinician?
Complying with the MACRA law essentially boils down to making a series of business decisions, and you begin by knowing which of two practice types you have: either above or below the low-volume threshold of $30,000 (traditional Medicare-allowed charges) and more or fewer than 100 unique Medicare patients per year. If you are above these thresholds, then you will be included in Medicare’s Quality Payment Program under the Merit-based Incentive Payment System (MIPS).
If you are below the low-volume threshold, your fee schedule will not be negatively affected. But you do have the option to voluntarily participate and may be included in the program when the threshold is lowered— because it will be lowered in the near future as stated by the final rule.
Accordingly, you can decide whether to participate or not, but your level of reimbursement could be reduced either due to lack of performance or participation, according to the law.
Wins across the board
Why would you want to participate in the new payment system? For those above the threshold, one obvious benefit is the positive payment adjustment to the fee schedule from 4 to 9 percent over the next several years (and potentially three times that amount for exceptional performance).
Quality measures allow both the clinician and the third-party payer to identify health risks and clinical findings that determine the health status and outcome of a patient’s condition. These quality measures, once collected, can give you the opportunity to develop systems of care.
This allows for more revenue streams into the practice. Even if you find yourself below the low-volume threshold, you can take advantage of collecting quality measures to bring patients to better health.
Considering this, choose quality measures and improvement activities that align with your practice’s patient population and clinical workflow.
Determining the clinical activities needed for the quality measures you choose involves understanding how often (and when) you need to collect the data and which encounter codes you will bill to validate the quality measures.
This particular decision is both a clinical and business decision. Studying specifications (known as the “rulebook”) for each measure gives you important information: the benchmarks, age of the patient population, etc. These rules change every year, so this is a process that you will undertake annually and making the right selection is critical.
How should this data be reported to CMS? Most clinicians are familiar with the Physician Quality Reporting System (PQRS) via claims. But now that there are reporting categories for quality, advancing care information, and improvement activities, claims-based reporting is less efficient.
Reporting through a qualified registry (QR) or a qualified clinical data registry (QCDR) is more appropriate. These registries connect with your EHR software and deliver it to Medicare. QCDR has the additional purpose of using the data to help improve care processes.
The most compelling reason to be involved in the new payment system is the fact that value is placed on the performance of quality measures. These quality measures offer the opportunity to develop additional revenue, while providing a new service line to the practice and better quality of care for the patient.
An EHR system is central to the success of this new practice design. By 2018, your EHR must be 2015 certified. Also, your EHR system must have the necessary quality measures you have selected to be successful. And it needs to be able to connect to a qualified registry or a QCDR to report directly to CMS.
The impending impact of MACRA represents a huge opportunity for some chiropractic practices. Will yours be one of them? Do your homework and use the necessary tools to succeed in the new payment system.
Scott Munsterman, DC, FICC, is founder and CEO of Best Practices Academy (BPA) and an expert on the transforming model of healthcare delivery, with a commitment to the promotion and advancement of the chiropractic profession. BPA assists chiropractic physicians to focus on growth, risk management, technology, and quality improvement. He can be contacted through bestpracticesacademy.com.