MACRA Volume Threshold Exempts Many M.D.s From 2017 Reporting
Abstract
APA is undertaking a major educational effort to guide members through the new system.
A significant number of APA members are likely to be exempt from reporting requirements for the Medicare Incentive Payment System (MIPS), which goes into effect January 1, 2017.
Initial analysis by APA staff of the final rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA) indicates that the “low-volume threshold” defining the minimum patient volume required for clinicians to report is high enough to exempt many psychiatrists—particularly those in small group practices—from reporting in the first year.
Specifically, a clinician or practice group that has “Medicare Part B allowed charges less than or equal to $30,000 or provides care for 100 or fewer Part B-enrolled Medicare beneficiaries” is exempt from reporting, according to the final rule. The rule was issued by the Centers for Medicare and Medicaid Services (CMS) on October 19.
MACRA is the sweeping Medicare reform law that creates a new value-based reimbursement system—the MIPS—and replaces the sustainable growth rate. MIPS also combines several previous quality-reporting programs into one new system designed to reimburse physicians for the value of services they provide rather than the volume of patients they treat. (In-depth information about MACRA and MIPS and a series of Psychiatric News articles about value-based payment.)
APA staff who have analyzed the final rule emphasize as well that clinicians who have been reporting quality data under the previously existing programs will not find the new system very different. Nevertheless, the new law represents a dramatic transformation of the Medicare reimbursement system, and APA staff have fielded comments from members expressing apprehension about how to navigate the changes.
The initial analysis should come as a relief to many. According to estimates in the final rule, the low-volume threshold should exempt 49 percent (16,521) of the 33,632 psychiatrists who see Medicare Part B beneficiaries. Psychiatrists who enroll as providers in Medicare for the first time in 2017 will also be exempt.
For those required to report, there is a variety of options from which to choose for reporting, including—in some cases—declining to report and accepting penalties for that year. Psychiatrists can ease into MIPS reporting in 2017 due to relaxed “Pick Your Pace” reporting for that year. Reporting just one measure under Quality, one Clinical Practice Improvement Activity, or all measures for electronic health record (EHR) use will avoid 2019 penalties. Reporting complete MIPS data for part or all of 2017 can earn modest (or slightly higher) bonuses in 2019.
Additionally, psychiatrists who report for 2017 will not be penalized for seeing sicker, lower income patients. Medicare patients’ cost or resource utilization will not be counted in clinicians’ MIPS score for 2017.
Finally, psychiatrists will have to report only four medium-weight or two high-weight Improvement Activities and only five Advancing Care Information Measures (for EHR) use to get credit in those categories. Look to future issues of Psychiatric News for further guidance on MIPS reporting. (For a short description of the different reporting categories, see box at left).
APA is creating educational materials to help members navigate the new system, including a downloadable MACRA Toolkit and a series of payment reform webinars. Members can learn more at www.psychiatry.org/PaymentReform.
The low-volume threshold established in the final rule appears to reflect the success of APA advocacy efforts to persuade CMS to protect clinicians in small group practices.
“APA staff are committed to helping our members navigate the new Medicare payment system,” said APA CEO and Medical Director Saul Levin, M.D., M.P.A. “Our initial analysis indicates that the Obama administration has heard our concerns so that clinicians—especially those serving Medicare patients in small group practices—will be brought over time into the new system. APA exists to help its members, and I encourage our members to consult APA’s website at www.psychiatry.
org/PaymentReform as we develop resources to help psychiatrists navigate the new system of reimbursement.”
CMS has indicated that the low-volume threshold will “evolve over time” and will be monitoring its effects, but it is now a part of the MACRA regulations. Any changes must take into account the views of stakeholders and the public.
Patient volume is determined during either of two 12-month periods—September 2015 to August 2016 or September 2016 to August 2017. CMS will calculate patient volume using providers’ National Provider Identifier (NPI) and/or the practice group TIN (Tax Identification Number) level. Psychiatrists who bill under a TIN for a group exceeding the low-volume threshold will be subject to MIPS requirements for billings through that group.
According to the final rule, CMS plans “to provide an NPI-level lookup feature prior to or shortly after the start of the performance period that will allow clinicians to determine if they do not exceed the low-volume threshold and are therefore excluded from MIPS. More information on this NPI feature will be posted at QualityPaymentProgram.cms.gov.” ■
