On October 14, 2016, CMS released its final rule for the Quality Payment Program (QPP) authorized by the Medicare Access and CHIP Reauthorization Act (MACRA).
Kentucky REC presented a MACRA Overview webinar to help organization’s understand how this will impact the way they deliver care.
To listen to the webinar, please click here.
The following questions were asked on the webinar. We have answered the Frequently Asked Questions below.
Please note: If you asked a question and do not see an answer here, please contact us directly and we will be more than happy to speak with you.
1. Are anesthesiologist excluded from MIPS?
Anesthesiologist may be exempt from participating in the MIPS program or certain categories of the program dependent on the place of service codes billed. Once CMS has the NPI lookup feature available you will be able to use this tool to find out for sure. However, until that time, it would be important to evaluate the percentage of “patient facing” encounters the provider has during 2016 to determine eligibility outside of the standard low volume threshold.
2. If we have a high percentage of Medicaid patients, do we need to worry about MACRA?
MACRA exclusions are based on volume, not percent of revenue, so we would suggest you check the dollar amount. An Eligible Clinician (EC) is excluded if he/she bills less than $30,000 or sees less than 100 Medicare patients.
3. How are providers identified as working in an FQHC so they won’t get a penalty for not reporting?
CMS will look at three snapshots of time from 2016 to determine eligibility. If the provider meets the low volume threshold of less than $30,000 Medicare Part B and/or less than 100 Medicare patients then they would be excluded. Traditionally, FQHC providers would not bill Part B outside of ancillary services. However, it is critical that you verify each provider to ensure avoidance of penalty.
4. We are an RHC, are we excluded from participating in MACRA/MIPS?
While RHC payments billed under the all-inclusive payment methodology are excluded, any Medicare Part B payments are included. This would typically include anything billed under ancillary testing (Lab, Radiology, etc). We would encourage you to look at your Medicare Part B billings and determine if your providers have billed less than $30,000 or seen less than 100 patients to be excluded. This would be per provider, if reporting on an individual provider level, or at the group level, if group reporting.
5. We are in an ACO (that is not considered an advanced Alternative Payment Model). Do we still have to participate in MACRA?
Yes, ACO participants are required to report under MACRA. There is not a separate reporting option for the Quality Performance category, as that is reported through your ACO. You would still report on the ACI and IA categories.
6. We are part of an ACO and attesting to PCMH this year, are we under MIPS or APM?
Unless your ACO is considered an advanced Alternative Payment Model, ACO participants are MIPS eligible.
7. We treat nursing home residents and patient engagement is our biggest challenge. The 5% for ACI will be tough. Any advice?
One suggestion is to partner with those nursing homes and see if they will assist in talking about the benefits of the patient portal. Use fliers/brochures to help keep the message in front of patients and families. Have your care team members, most importantly the physicians, talk about the portal. Studies have shown that patients are more responsive if their physician asks them to use the portal versus other staff members.
8. Any guidance on successful strategies to improve patient utilization of portals? Can you provide more information on the “opt-out” option? Is this a viable solution to meeting this requirement?
One of the best strategies to improve use of patient portals is to have the physician engage the patient in discussing portal benefits. Many physicians are encouraging patients to use the portal to request/cancel appointments, request prescriptions on medications when refills expire, and to send private messages to care team members. All these options depend upon the functionality of your particular portal vendor. One caveat to the “opt out” option-you must have a way to show a list of patients who “opt-out” and most systems do not yet have this ability automated. Therefore, you would need a manual process to provide documentation if ever audited.
9. Are psychologists considered Eligible Clinicians?
Under MIPS, psychologists are not considered Eligible Clinicians (ECs) in performance years 2017 and 2018. They should plan on reporting in 2019 (for payment year 2021). While it is not required, it might be beneficial to begin reporting prior to 2019 as a way for the provider to receive feedback and begin implementing strategies that would strengthen their score by 2019.
10. We cannot report using the public health reporting (KHIE) due to the costs constraints. How can you help?
For Advancing Care Information, there is no longer an “all or nothing” approach. Therefore, not having connectivity to KHIE or a public health organization will not prevent you from successful participation.
11. Is full year reporting required to be eligible for part of the $500 million pool for scoring greater than 70 points?
No, a full year is not required. However, a full year reporting period could increase your chance to achieve a score of greater than 70. It is important that you evaluate your reports prior to submission to determine the best submission methods and performance periods.
12. Is the low volume threshold only for one year?
The low volume threshold is based on a “look back” of your previous year’s activity.
13. Is the low volume threshold per provider or per organization?
It depends on how you plan to report. If you do individual reporting, then it is per provider. However, if you plan to do group reporting, then it would be collective for your group.
14. Does MACRA only apply if we are applying for the Medicare EHR Incentive Program? If we are applying for the Medicaid EHR Incentive Program can we also participate in the Medicare EHR Incentive Program?
MACRA is the legislation that created the Quality Payment Program which encompasses the PQRS program, the Medicare EHR Incentive Program and the Value Modifier. If a provider is an Eligible Clinician then the provider would need to participate in one of the two tracks: MIPS or Advanced APM. In addition, if the provider participates in the Medicaid EHR Incentive Program, then the provider can continue to participate in that program through 2021. However, this would require the provider to attest to both one track of the QPP program as well as the Medicaid EHR Incentive Program to avoid penalty and potentially qualify for the Medicaid EHR Incentive program monies.
15. I currently participate in the Medicaid EHR Incentive Program. Do I also have to participate in MACRA?
Medicaid EHR Incentive Program will continue through 2021. If you would like to continue to participate in the Medicaid EHR Incentive Program, you can do so, but it will require dual attestation (MU requirements for Medicaid Program and ACI requirements for QPP Program).
16. Is ACI reporting at the organization level?
ACI reporting can be done at the TIN level or individual NPI level. Depending on the size of your practice and the vendor you use for data capturing, you may have a group level report that can be pulled to determine the group’s performance.
17. How will we attest for MACRA?
Currently there are several different methods to use to submit data for the MIPS program. Check out the QPP.CMS.GOV website to learn more.