Recently, the Office of the Federal Register published an update on MIPS along with changes that will impact value based healthcare and providers who accept Medicare Part B reimbursements.
These changes were announced in response to public comments Centers for Medicare & Medicaid Services (CMS) received on proposed MACRA regulations. Generally speaking, this final ruling attempts to address the concerns of small practices and clinicians who are unsure about MACRA’s changes and how to participate in reporting.
This may make it easier for your practice to report within the MIPS program and may help you avoid receiving a negative payment adjustment next year. With the final ruling, CMS is allowing an exemption for providers who see fewer than or exactly 100 patients per year or receive $30,000 or less in Part-B reimbursements.
Clinicians who are required to participate in 2017 have a range of different options to do so. Non-participation comes with a negative 4 percent penalty if you are required to report during the first year and fail to.
To avoid penalties, you should seriously consider the options available to you and your practice. Research your participation requirements carefully before you decide and enlist professional advice if needed. Find out the Final Ruling’s implications for you and start 2017 off right.¹
Types of participation
For clinicians who are required to participate in MIPS, there are several different options depending on the level of reporting you are able to do or interested in doing. You have the following choices:¹
- Report for 90 days or for the entire year
Your first option is full participation. You can report each measure just as if 2017 is a normal MIPS participation year and file a complete report. The advantage to this is it provides you with your best chances of receiving a full incentive.
- Report for more than 90 days (less than one year) and submit more than one measure
You can choose to begin partial reporting during 2017 and gradually phase-in MIPS reporting requirements at your clinic. You may not qualify for the full incentive.
- Report one measure
Reporting at least one measure allows you to avoid a negative adjustment for 2017. This can be a quality measure, improvement activity, or advancing care information reporting.
- Do not submit a report
You can also skip reporting altogether, although you will receive a 4 percent negative adjustment if you do so.
- Participate in an Advanced APM
Finally, the last option for clinicians is participating in an Advanced APM. These are special care models, such as patient-centered medical homes.
As the two transition years begin, other changes will gradually be adopted under MIPS. New ways to file reports will become available, such as grouping small practice reporting together for practices with fewer than ten clinicians.
CMS hopes to gradually roll out these and other changes as broader adoption of MIPS occurs and everyone has a chance to see how this new legislation impacts healthcare. You should be aware of these upcoming changes whenever possible and be ready to implement changes in your own practice.
In 2017, CMS expects that 90 percent of clinicians eligible for MIPS will receive either a neutral or positive adjustment to their reimbursements. Because many smaller practices are not even required to report during the transition years, the majority of chiropractic clinics may find that MIPS provisions do not impact them yet.
Regardless of how MIPS effects you right now, you should investigate how MIPS works and determine how this legislation changes your reporting requirements. Avoiding penalties is one incentive of MIPS, but the potential of earning a positive adjustment may be a significant reward for practices with Medicare patients.
The more information you have about MIPS, the better you can plan ahead for the new changes and prepare yourself. Getting accurate information and staying updated about this new legislation may just save you money and help you deliver better care.¹
¹CMS. “Medicare Program; Merit-Based Incentive Payment (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician-Focused Payment Models.” The Federal Register. CMS. https://www.federalregister.gov/documents/2016/11/04/2016-25240/medicare-program-merit-based-incentive-payment-system-mips-and-alternative-payment-model-apm. Published: November 2016. Accessed: November 2016.