MACRA: Jaw-Dropping Updates for the 2018 Performance Year Part 2

In Part 1 of this series we learned that for the 2018 Performance Year, MIPS eligible clinicians will be allowed to participate in Virtual Groups. Additionally, we learned that the low-volume threshold will be increased to < $90,0000 in Part B allowed charges or < 200 beneficiaries, you will be excluded from the MIPS Payment track with no risk of a negative payment track. You can read about these updates and more here: MACRA: Jaw-Dropping Updates for the 2018 Performance Year Part 2.

This week we will discuss updates that affect reporting options in addition to proposed implementation of facility-based measurement. We’re also going to potentially earn bonus points for complex patients and for practices with 15 or fewer clinicians. Let’s get started breaking it down.

Reporting Mechanisms

For the 2017 Performance Year MIPS eligible clinicians are to use only one submission mechanism per performance category. To clarify, for the Quality category, all six measures you choose must be submitted using the same mechanism, whether that’s with an EHR, a registry or claims does not matter. Additionally, all Improvement Activities must be attested to the same way.

For the 2018 Performance Year the proposed change will allow both individual eligible clinicians and groups to use multiple submission mechanisms within any performance category that is applicable to meet the requirements. Basically, you can choose any quality measure that is relevant to your practice regardless of the reporting mechanism that is required. The same applies to the Improvement Activities category and the Advancing Care Information category.

Facility-Based Measurement

This update to the 2018 Performance Year was not available in 2017. The proposed change would only apply to facility-based clinicians who have at least 75% of their covered professional services supplied in the inpatient hospital setting or emergency department. CMS is suggesting the implementation of an optional voluntary facility-based scoring mechanism based on the Hospital Value-Based Purchasing Program. This option would convert a hospital Total Performance Score into a score for the MIPS Quality category and the Cost category.

If you’re unfamiliar with the Hospital Value-Based Purchasing (VBP) Program, it is a CMS initiative that rewards acute-care hospitals with incentive payments for the quality of care they provide to Medicare beneficiaries. The program began with the start of Fiscal Year 2013. This approach amends payments to hospitals with an increasingly severe schedule. In 2013 1% of the Medicare payments to all hospitals were impacted. That grew to 1.25% in 2014.

Complex Patient Bonus

In 2017 there were no bonus points available for practitioners who treated beneficiaries with more complex conditions. CMS has proposed that an adjustment of “up to” 3 bonus points by adding the average Hierarchical Conditions Category (HCC) risk score to the final score. In general, the HCC relates to medical billing codes that are used only for life-altering medical conditions like diabetes, end-stage renal disease, etc. What that means is that a clinician would earn between 1 to 3 points based on the complexity of the patients they treat.

Small Practice Bonus

Once again, this bonus is not available for the 2017 Performance Year. However, for 2018 CMS proposed that the final score of all eligible clinicians or groups who are part of a small practice be adjusted by adding 5 points to the final score. They have defined small practice as a practice with 15 or fewer clinicians. CMS is also considering this bonus for rural health providers as well.

Conclusion

Come back for Part 3 and we will break down the updates to each individual performance category. There are potential changes to the requirements and also to the weight of each category to the total Composite Performance Score. You won’t want to miss this information! You can also hear it clearly explained at our next MIPS Guide to Success Webinar. Register Here.