Medicare Threshold Changes
The final rule was released on November 2, and the most notable change exempts even more clinicians from the Merit-Based Incentive Payment System (MIPS) track in 2018, the track in which urgent care clinicians are most likely to participate.
The QPP was established under MACRA, or the Medicare Access and CHIP Reauthorization Act of 2015, and MIPS is one of the payment tracks under the QPP. The other track is the Advanced Alternative Payment Models or APMs.
Now providers and groups with less than $90,000 in Medicare Part B allowable charges or fewer than 200 unique Medicare patients per year are exempt from MIPS. Originally, the threshold was $30,000 in Medicare Part B allowable charges or fewer than 100 Medicare patients per year. Modern Healthcare reports that “officials with the CMS said they were responding to many practices' concerns that they didn't have enough Medicare patients to justify the cost of overhauling their electronic health record systems or buying new ones to track and report quality measures.”
Because most urgent care centers see only about 10 percent Medicare patients, the likelihood that many urgent care clinicians will meet this new threshold for MIPS is quite unlikely. According to Modern Healthcare, the revised threshold will exempt a total of 934,000 providers from the MIPS program.
No EMR Upgrades Needed Just Yet
CMS says it’s trying to reduce the burden of implementing the QPP in year two, and one of the ways it’s doing this is by giving physicians more time to upgrade their EMR/EHR technology. MIPS-eligible urgent care clinicians may be relieved to hear they can continue using 2014 edition certified electronic health record technology (CEHRT) in year two to report the Advancing Care Information (ACI) transition measures. However, urgent care physicians who use a 2015 edition CEHRT could be eligible for a bonus.
It’s worth noting that a bill was introduced to Congress just last month that could make meaningful use compliance much easier in the future. H.R. 3120 was written to amend the Social Security Act to “reduce the volume of future electronic health record-related significant hardship requests.”
What does this mean? Well, the HITECH Act amended the Social Security Act to require the Health and Human Services (HHS) Secretary to make meaningful use requirements more “stringent” over time. In the minds of lawmakers, this would encourage health care providers to ramp up their EHR use. H.R. 3120 simply removes the amendment requiring the HHS secretary to make meaningful use requirements stricter over time.
According to Modern Healthcare, “If Congress passes the bill, it could make meaningful use compliance easier for providers and help them avoid penalties. That in turn could cut down on providers' significant hardship requests when they can't attest to meaningful use because their electronic health records are lacking.”
The bill passed the House in early October and is awaiting a Senate vote.
Considerations for Hurricane Victims
CMS is acknowledging the extreme and devastating impacts of Hurricanes Harvey, Irma and Maria, which all occurred during the 2017 MIPS performance period, by adding an “extreme and uncontrollable circumstances” policy for the transition year and the 2018 MIPS performance period. The policy includes situations such as hurricanes, natural disasters or public health emergencies and applies to MIPS-eligible clinicians but not the Advanced Performance Measures (APMs) program.
This essentially means that MIPS-eligible urgent care physicians in hurricane-affected areas can submit a hardship exception application so they do not need to submit 2017 MIPS data, and they’ll automatically avoid the 2019 penalty. However, they can opt to submit 2017 MIPS data and receive a MIPS payment adjustment based on category-by-category performance to get a positive payment adjustment similar to other eligible clinicians.
Comment on the Final Rule
CMS is currently taking comments and feedback on the QPP year two final rule. Email QPP@cms.hhs.gov. Put CMS-5522-IFC in the subject line.
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