Medicare is attempting to move from fee-for-service to value-based purchasing with the goal of paying for value and better care. They will do this, with or without comments from us.

However, in establishing this new program, they appear to be listening to and incorporating the thinking of those affected by the program—especially clinicians. This is your chance to be heard.

Here are two proposals that will affect you if you are a practice without a reporting module or the resources to extract data from your EHR database—especially small practices without an EHR on paper records.

1. There is a lack of clarity to know if Measure Groups will continue to be a viable reporting mechanism for MIPS. It appears that reporting on just 20 patients might not be an option and you would have to follow the rules for reporting individual measures.
2. Reporting as an individual or a group, using individual measures, instead of reporting on 50% of your eligible patients, you will be required to report on 90% of ALL patients from all payers. Since a cross-cutting measure will still be required, and cross-cutting measures, by definition, are broadly applicable to almost all your patients, this means that you could have to report on every single patient in your practice.

These two changes significantly increase the workload to successfully submit data for the Quality Performance Category. Given our experience, the burden of reporting for these types of practices—on paper, or without reporting from their EHR will be ENORMOUS.

Here’s how to comment:

1. Prepare your comments. Be as specific as possible as to how these changes would affect your practice.
2. Go to: https://www.regulations.gov/#!documentDetail;D=CMS-2016-0060-0068
3. Select: the “Comment Now” button on the right.

If you provide feedback to Medicare, please send it along or post them here in the comments. We would love to know how the proposed rule will impact you.

MIPS and ACO Reporting under the Quality Payment Program

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