Modern Healthcare has reported that Andy Slavitt, acting administrator of CMS, has suggested in a Senate Finance Committee hearing that the Quality Payment Program created under MACRA could be delayed beyond the proposed January 1, 2017 start date.
In addition, Healthcare Informatics stated that “the MACRA law gives CMS the flexibility to move the start date of the reporting period back“ and indicated that various groups representing physicians have expressed major concerns about small practices not being prepared for the changes.
Our feeling, here at Mingle Health, is that in general the new Quality Payment Program and Merit-Based Incentive Payment System (MIPS), created by MACRA, are a major improvement over the previous programs of PQRS, Value Modifier and Meaningful Use.
The mix of PQRS, VBM and MU created a complicated set of requirements including:
- Confusing time frames
- Overlaps in requirements
- Wasted resources
- Inconsistent measurement and payment adjustments
The Quality Payment Program, as proposed, makes a significant improvement to address those issues.
There are, however, two major provisions in the proposed rule that are contributing to the concerns that small practices will not be able to succeed under MIPS.
The Proposed Rule eliminates Measure Groups as a reporting option in the Quality Performance Category. Around here we fondly refer to Measure Groups as “CMS’ gift to small practices” because they require just a 20-patient sample to report successfully. Without Measure Groups, those practices will be forced to report using individual measures with a much higher reporting requirement, which in the Proposed Rule is called “completeness criteria.”
The proposed “completeness criteria” for Registry and EHR reporting is 90% of all payers, a significant increase from the previous criteria of reporting 50% of Medicare Part B patients only.
Though there may be other proposals in the rule that contribute, we feel these two items are the biggest reason that smaller practices will have a hard time succeeding in the Quality Performance Category under MIPS.
Bring back Measure Groups as an option and retain the completeness criteria under PQRS of 50% of Medicare Part B patients only.
With those two provisions, and perhaps with some additional tweaking, we have a solid Quality Payment Program that advances CMS objectives of payment reform and is a huge improvement over the three programs it replaces.
Do you feel your practice is ready for MIPS? Share your thoughts in the comments.
Your introduction to MACRA, MIPS, APMs and the future of Medicare reporting.