We’re almost four months into the 2017 reporting year for the new MACRA Quality Payment Program (QPP), but many providers still aren’t sure how to participate or whether they even need to. If that describes you, don’t worry. You’re not alone.
According to a February 2017 survey conducted by Stoltenberg Consulting during the HIMSS Conference, two-thirds of the 300 healthcare and health information technology professionals surveyed were not prepared for MACRA. About a third said their top quality challenge right now is “revising data management and reporting processes to meet MACRA requirements.”
But the onus for preparing for the QPP is not entirely on providers. On March 15, 2017, the Medical Group Management Association (MGMA) sent a letter to Seema Verma, administrator of the Centers for Medicare and Medicaid Services, urging her to provide basic information providers need to participate in the Merit-Based Incentive Payment System (MIPS) option. According to MGMA, at that time, CMS had failed to notify providers of basic eligibility data and their status as hospital-based or non-patient-facing providers, and had not published approved lists of registry vendors.
“This is generating considerable frustration and confusion,” Anders Gilberg, MGMA senior vice president of government affairs, wrote. “Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program.”
Since then, CMS did release a list of Qualified Registry vendors on April 14, 2017, though the list of vendors and available measures for the Qualified Clinical Data Registry (QCDR) reporting option still have not been released.
Also, the April 27, 2017, MLN Connects indicates that CMS has begun reviewing claims in order to determine provider eligibility, and will be “letting practices know which clinicians need to take part in the Merit-based Incentive Payment System” via letters being sent in late April through May by the respective Medicare Administrative Contractors. Those letters will indicate the participation status of each clinician by Taxpayer Identification Number (TIN).
Generally, clinicians are required to participate in MIPS in 2017 if they:
- Bill more than $30,000 in Medicare Part B allowed charges a year and
- Provide care for more than 100 Part B-enrolled Medicare beneficiaries a year
A MIPS Participation Fact Sheet also was updated on April 6, 2017, on the Education and Tools page of the QPP website, including information about the participation requirements for providers serving at Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and Critical Access Hospitals (CAHs).
So far, there is no indication when or how providers will be notified of their status as “hospital-based” or “non-patient-facing” providers.
While it’s been difficult for some providers to know what steps to take to participate in MIPS in 2017, the good news is that under the “pick your pace” provision CMS offered, even minimal participation (as little as submitting one quality measure for one encounter) will allow providers to avoid a 4 percent negative payment adjustment. Whether providers will be able to participate more fully and potentially earn an incentive will depend, at least in part, whether CMS can get the information to them in time.
For more information and updates on the QPP program, visit the QPP webpage, which is being updated regularly with new information, and subscribe to the QPP email list to receive the latest Quality Payment Program updates directly from CMS (subscription option available in the footer of the QPP webpage).
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