The year is not over yet. So that means there is still time to take action to avoid Medicare payment penalties, prepare for a strong 2018, and maybe even do some shopping.
Physicians who chose the minimal participation option for 2017 have until Dec. 31 to complete the “one patient, one measure, no penalty” process and avoid a 4 percent negative payment adjustment for Medicare in 2019. The AMA offers a step-by-step guide on how to successfully complete the process.
To help select a quality measure to report on, the Centers for Medicare and Medicaid Services (CMS) offers a Quality Measures Search Tool.
CMS will accept physicians’ data between Jan. 2 and March 31, 2018. For physicians submitting claims, which include those who choose the one patient-one measure option, there is a Feb. 28, 2018 deadline to submit data.
Under the Medicare Quality Payment Program (QPP), performance in 2017 affects payment in 2019, while performance in 2018 will affect payment in 2020.
Physicians have until Dec. 31 to apply for a hardship exemption for 2017 in the Advancing Care Information (ACI) category. This category replaces the legacy Meaningful Use program for health information technology. A physician may qualify for a hardship exemption and have the category reweighted to zero percent of the QPP’s Merit-based Incentive Payment System (MIPS) score under these circumstances:
- Insufficient internet connectivity.
- Extreme and uncontrollable circumstances.
- Lack of control over the availability of certified electronic health record technology.
CMS has more information on how to apply for a hardship exemption.
Hurricanes Harvey, Irma and Maria qualify as a “triggering event” that automatically grants extreme and uncontrollable circumstance hardship exemptions across all MIPS categories. All physicians in Florida, Georgia, Puerto Rico and the U.S. Virgin Islands have been granted hardship exemptions as a result of the hurricanes—as have physicians in several Louisiana, South Carolina and Texas counties. Physicians in several Northern California counties have also been granted exemptions for the wildfires that burned in their region. If you are interested in earning an incentive, you still have the option to participate in the 2017 QPP program.
Under their hardship status, physicians in the affected areas avoid MIPS penalties, but are also ineligible for potential bonuses unless they choose to submit data. If they choose to submit data, the exemption no longer applies—meaning, if it appears their practice will receive a negative payment adjustment, they cannot withdraw the data and return to their exempt status.
Test your 2018 data-collection tools and processes. Physicians should check to make sure the data-collection methods they will be using in 2018 are able to process and submit a full year’s worth of quality information starting Jan. 1, 2018.
Data-collection vendors may also have their own specific requirements. Physicians need to work with their vendors to ensure they are able to collect all necessary quality data as soon as the new year starts.
Physicians who choose to report quality data using their claims for payment should review their coding and data-collection processes to be sure they are ready to start submitting data on Jan. 1.
Select quality measures for 2018. Physicians who want to participate fully in MIPS in 2018 need to choose at least six quality measures—or a full specialty data set—to collect data on. They also need to understand the numerator, denominator and data-completion rules that apply to each one. Physicians can, however, participate partly in multiple MIPS tracks to achieve the minimum points and avoid a penalty.
Most quality measures from 2017 will still be valid, though CMS did add, remove and modify certain measures for 2018. Specifications for these changes were published in the Federal Register. Physicians reporting via a Qualified Clinical Data Registry should check to see if the vendor has added, modified or changed the quality measures they are reporting on the physician’s behalf.
Decide whether to join a virtual group for 2018. Solo practitioners or practices with 10 or fewer eligible clinicians who are participating in MIPS can work together as a virtual group next year. But they must apply to create a virtual group by Dec. 31, 2017. CMS has additional information on forming a virtual group.
The QPP was created by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The AMA’s MACRA Resource Center offers guidance on navigating the new payment system, including a podcast series on ReachMD.
The QPP remains a work in progress, but the AMA continues to work closely with CMS to ensure that the regulations implementing the program are less onerous than under prior law, contain lower penalties, provide an opportunity for upside incentive, and include a workable transition for physicians.