Although the 2018 final rule for the federal Quality Payment Program (QPP), MACRA (the Medicare Access and CHIP Reauthorization Act), did not hold big surprises, certain aspects of MACRA Year 2 still pose confusion for eligible clinicians.
Now that we’re six months into MACRA Year 2, it’s a good time for eligible clinicians (ECs) and physician practices to assess their progress and determine where increased education and focus are needed.There are four ways providers can close their knowledge gap around MACRA Year 2 requirements and position themselves for strong performance.
1. Understand your quality measures. Halfway into MACRA Year 1, an American Medical Association survey found 75 percent of eligible physicians didn’t feel well prepared to meet its reporting requirements. Three months later, our internal survey of customers across 40 specialties found 27 percent still did not know what quality measures they were reporting. Given the financial penalties at stake, it’s critical that ECs and physician practice administrators are highly familiar with the quality measures they are reporting on well before the results are shared with the Centers for Medicare & Medicaid Services (CMS).
This year, most ECs are participating in the Merit-based Incentive Payment System (MIPS) track of MACRA, rather than the Advanced Alternative Payment Model (APM) track. Under MIPS, clinicians will see a payment adjustment ranging from plus-or-minus 5 percent for the 2018 performance year. Successful completion of the APM track enables eligible clinicians to earn a 5 percent incentive for achieving performance thresholds.
Fifty percent of an EC's MIPS score is based on quality performance, and this year, clinicians must report on at least six quality measures, including an outcomes measure, for a full year. If an outcome measure is not available, ECs must use at least one other high-priority measure or a specialty measure set.
Action steps for ECs and practice administrators include the following:
• Review the measures you have selected to become familiar with how to apply and correctly code the measures.
• Ensure your billing software and clearinghouse can correctly submit quality data codes (QDCs) to the carrier on your behalf.
• Regularly review the remittance advice notice you receive from the carrier or Medicare Administrative Contractor to ensure the denial remark code N365 is listed for each QDC submitted.
2. Be aware of the change in MIPS quality reporting requirements. This year, not only must clinicians report on six quality measures, but it must be through a single submission reporting method, not a combination of methods. Reporting methods includethe Qualified Clinical Data Registry (QCDR), a qualified registry, an electronic health record (EHR), claims, or—for groups of 25 clinicians or more reporting as a group—a CMS web interface. Reporting for quality and cost includes year-long data while promoting interoperability (PI), formerly known as advancing care information (ACI), and improvement activities (IA), requires a minimum of 90 days’ worth of data.
And, it is possible for ECs to report on more than six quality measures. However, to meet MACRA requirements, six measures must be reportedthrough a single reporting mechanism.
3. Determine which reporting method holds the greatest benefit for your specialty. Clinicians who report on MIPS quality measures through their EHR used to have 64 quality measures to choose from; now, there are only 55. Yet, clinicians who report on quality measures through a qualified registry have nearly 300 measures to choose from.
The limited EHR quality reporting options put specialty ECsand practices at a disadvantage, forcing some specialty clinicians to report on quality measures that are not meaningful to their work. For example, orthopedic physicians currently may report on “screening for high blood pressure” as one of their six measures, while urologists may report on the number of women ages 50-74 who underwent mammograms to screen for breast cancer. Because these are not items the example specialties focus on, reporting these could do more damage than good to their scores.
Further complicating the issue is that clinicians receive a bonus point for reporting through the EHR. Additionally, benchmarks for a single measure differ based on the submission method.
These are disparities CMS is working to address in 2019.
4. Know when to report as an individual and when to report as a group. While it’s too late to report as a virtual group (providers had to voice their intention to do so by December 2017), ECs in physician practices still have time to decide whether they will report on their performance individually or as a group. Theoretically, if the clinicians in your practice report on their performance individually, each clinician could receive a plus-or-minus score in MACRA Year 2. However, under a group-reporting structure, your practice will receive one payment adjustment based on the group’s performance. It is important to keep in mind high-performing clinicians who have a low performer in their group may be irritated with a group reporting structure in which their score is penalized by the performance of one clinician.
It’s important to assess where individual clinicians’ performance falls under the MACRA Year 2 requirements and the extent to which a low performer could pull down the performance of the group. With this information in hand, practices would still have time to provide support that could elevate a low performer’s performance. Later in the year, practice administrators should then regroup to determine the ramifications of individual-vs.-group reporting for their practice.
Boosting Your Chances for Success
It’s not too late to adjust your approach for improved performance under MACRA Year 2. Taking the time to assess your progress now and determine where gaps in knowledge or processes exist could make a tremendous difference in the payment adjustment you receive in the 2020 payment year.
Sonya Bess is the Government & Regulatory Compliance Specialist at Pulse Systems, Inc.
