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MACRA 90-day reporting deadline approaching

Beginning with the 2017 reporting year, eligible physicians who do not participate in the Medicare Quality Payment Program (QPP) will see a negative 4 percent payment adjustment in 2019. QPP is the new physician payment system created by the Medicare Access and CHIP Reauthorization Act (MACRA) and administered by the Centers for Medicare and Medicaid Services (CMS).

During the 2017 transition year, CMS will allow physicians to select one of three “pick your pace” participation options. Participating at any level in 2017 will ensure that you will not be hit with the 4 percent pay cut in 2019.

The most lenient participation option—reporting on one patient, one measure—allows physicians to avoid a penalty by "testing" the program to ensure that their systems are working and that they are prepared for broader implementation in 2018 and beyond.

Physicians can choose to report for 90 days and possibly earn a small bonus payment. If you plan to select this 90-day reporting option, your performance period must begin no later than October 2, 2017.

Physicians can also choose, if they are ready, to report a full year of data in 2017 and be eligible to receive a modest bonus, depending on their performance.

Providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the reporting requirements in 2017. If you are unsure of your QPP participation status, you can look it up here.

FREE assistance for small practices
California physicians in practices of 15 or fewer can receive free assistance to prepare and participate in the QPP through the California Health Information Partnership & Services Organization (CalHIPSO). CalHIPSO will help you select the right participation “pace” for your practice, navigate the new landscape, assess performance data and stay informed about the QPP. Contact CalHIPSO now to register for services and receive no-cost technical assistance.

CMA MACRA Resource Center
To help physicians understand the payment reforms and prepare for the transition, CMA has published a MACRA resource page at www.cmanet.org/macra. There, you will find an overview of MACRA and a comprehensive list of tools, resources and information from CMA, the American Medical Association and CMS.

CMA urges CMS to further reduce MACRA administrative burdens

The California Medical Association (CMA) recently submitted comments on proposed 2018 changes to the Medicare Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Though not perfect, CMA is pleased that the Centers for Medicare and Medicaid Services (CMS) has listened to physician feedback and has made changes that will significantly reduce the administrative burdens on physicians, particularly for small and rural practices. We appreciate the agency’s responsiveness to many of our concerns about the ability of physicians to successfully participate in the QPP. 

Under the proposed rule, 2018 will be another transition year like 2017. This means that physicians who report only one quality measure in 2018 can avoid all penalties in 2020. CMS estimates that under the proposed 2018 MACRA rule, 94 percent of physicians will earn either a positive or neutral payment adjustment in 2020 for the 2018 reporting year. Thirty-seven percent of physicians are expected to be exempt because of the low-volume threshold. The proposal would also allow virtual groups and provide bonus points for physicians treating complex patients.

CMA is urging CMS to make additional changes to further reduce administrative burdens while allowing physicians to be innovative and improve care. Among the changes CMA is seeking are a reduction in the number of electronic health record (EHR) measures; expanding the adjustments for complex patients; removing the requirement to report all payer data; and exempting physicians within five years of retirement. CMA is also urging CMS to hold EHR vendors more accountable, particularly for interoperability.

Major highlights of the proposed rule include:

  • Continues 2018 as a “Pick Your Pace” transition year, during which physicians can easily avoid all penalties.
  • Provides additional accommodations for small and rural practices, including automatic bonus points for small practices.
  • Expands the total exemption to physicians with $90,000 or less in Medicare Part B allowed charges or 200 or fewer Medicare patients.
  • Allows virtual groups to organize and help small practices pool resources to report successfully.
  • Provides bonus points for physicians treating complex patients, including dual-eligible patients.
  • The flawed “resource use” (physician cost) category will not count again for the 2018 reporting year.
  • Continues to allow use of the 2014 edition of Certified Electronic Health Record Technology.
  • Provides new Advancing Care Information (EHR) hardship exemptions for physicians in small practices.
  • Provides exemptions from all Advancing Care Information (EHR) requirements if a physician’s EHR is decertified.
  • Provides new bonus points for Advancing Care Information (EHR) requirements.
  • Permits physicians to continue to report modified stage 2 meaningful use measures in 2018 instead of new stage 3 measures.
  • Provides new options to use facility-based scoring for facility-based physicians who provide more than 75 percent of their services in an in-patient setting or through the emergency department.
  • For Alternative Payment Models (APM), extends the current, more reasonable nominal financial risk requirement of 8 percent of total Medicare revenue for two more years.
  • Reduces the financial risk requirements for APM medical homes.
  • Reduces reporting burden for the Merit-Based Incentive Payment System and APMs

For more details on CMA’s proposed MACRA changes, see CMA’s full comments, which are based on the recommendations of our MACRA Technical Advisory Committee.

CMA will be working closely with the American Medical Association (AMA) and CMS to monitor the QPP’s effect on physician practices, the physician-patient relationship and access to care.

CMA MACRA Resource Center

To help physicians understand the MACRA payment reforms and prepare for the transition, CMA has published a MACRA resource page at www.cmanet.org/macra. There, you will find an overview of MACRA and a comprehensive list of tools, resources and information from CMA, AMA and CMS.

Free MACRA assistance for California physicians

The Health Services Advisory Group, in partnership with the California Health Information Partnership & Services Organization (CalHIPSO), is providing no-cost technical assistance to physician offices in California to help them prepare for and participate in the MACRA QPP. CalHIPSO is also hosting a CMA webinar on September 20 to answer physician questions about MACRA reporting.

CMS now accepting QPP hardship applications for 2017

The Centers for Medicare and Medicaid Services (CMS) is now accepting hardship exceptions from the Medicare Quality Payment Program (QPP) for the 2017 reporting year. Beginning with this reporting year, physicians who do not participate in QPP will see a negative 4 percent payment adjustment in 2019. Physicians who do participate may qualify for bonus payments.

Physicians and groups that qualify for the QPP’s Merit-Based Incentive Payment System (MIPS) can submit a hardship exception application for one of the following reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of certified electronic health record technology

If you meet one of the criteria above, you may qualify for a reweighting of the Advancing Care Information performance category score to 0. The 25 percent weighting of the advancing care information category would be reallocated to the quality performance category

There are also some MIPS eligible clinicians who are considered “special status,” who will be automatically reweighted (or exempted in the case of MIPS eligible clinicians participating in a MIPS alternative payment model) and do not need to submit a QPP hardship exception application.

Hardship exception applications can be submitted via the QPP website. You can also contact the QPP Service Center at (866) 288-8292 or QPP@cms.hhs.gov and work with a representative to submit an application.

Once an application is submitted, you will receive a confirmation email that your application was received and is pending, approved or dismissed. Applications will be processed on a rolling basis.

Physicians should also be aware that 2017 is a transition year, with CMS offering “pick your pace” options for participation. Participating at any level in 2017 will ensure that you will not be hit with payment penalties in 2019. The most lenient participation option would allow physicians to simply "test" the program to ensure that their systems are working and that they are prepared for broader implementation in 2018 and beyond. While physicians who choose this option will not receive bonus payments, they will avoid a negative penalty.

Providers with less than $30,000 in Medicare payments or fewer than 100 Medicare patients are exempt from the MIPS reporting requirements. Physicians who exceed this threshold are subject to MIPS and are encouraged to participate in MIPS for the 2017 transition year to avoid the negative payment adjustment. If you are unsure of your MIPS participation status, click here.

California physicians in practices of 15 or fewer can receive free assistance to prepare and participate in Quality Payment Program through CalHIPSO. For more information visit www.hsag.com/CalHIPSO.

The American Medical Association has also published a short instructional video to help physicians avoid being penalized under the QPP. The video offers step-by-step instructions on how to report on one patient for one measure to avoid a negative 4 percent payment penalty in 2019.

For more information about the QPP, implemented with the Medicare Access and CHIP Reauthorization Act (MACRA), visit www.cmanet.org/macra.

CalHIPSPO receives Medi-Cal EHR incentive program award

The California Department of Health Care Services has awarded the California Health Information Partnership & Services Organization (CalHIPSO), founded by the California Medical Association (CMA), the California Primary Care Association and the California Association of Public Health Hospitals and Health Systems, a Medi-Cal electronic health record (EHR) incentive program technical assistance contract for $15 million. Other organizations also given EHR technical assistance awards include the Health Information Technology Regional Extension Center, the CalOptima Regional Extension Center and Object Health.

Over the next three years, these organizations will assist more than 3,000 providers who are eligible professionals in the Medi-Cal EHR Incentive Program. Technical assistance will include areas such as patient portal and health information exchange implementation, as well as program assistance for progression through Meaningful Use Stage 2.  

CMA expects more information on these grants to come in early July 2015.

CalHIPSO seeks physicians to sign up for free practice transformation assistance

The California Health Information Partnership and Services Organization (CalHIPSO) is applying for a grant from the Center for Medicare and Medicaid Services (CMS) to give California physicians access to free health practice improvement tools and services that would normally be cost prohibitive. The California Medical Association was a founding member of CalHIPSO, which was established in 2009 as a federally designated Regional Extension Center to provide education, outreach and technical assistance to help physicians select and implement electronic health records.

To win this grant, CalHIPSO must show commitment and interest from providers (non-binding). To that end, CalHIPSO is seeking physicians and physician groups willing to submit an online form stating that they would benefit from assistance preparing for the new care delivery and payment models and quality initiatives, which, with limited resources, would be a challenge to accomplish independently. Physicians can alternatively send an email stating their interest, including their name, specialty, and NPI. Responses are requested by January 26, 2015.

The grant being applied for is part of the federal Transforming Clinical Practice Initiative, designed to help support 150,000 clinician practices over the next four years in sharing, adapting and further developing their comprehensive quality improvement strategies. Physicians who participate in this program will gain critical assistance to engage in new delivery models, such as medical homes or ACOs.

To find out more about the CMS initiative, click here. To find out more about the CalHIPSO grant application, visit the CalHIPSO website.

CMS conducts meaningful use audits in California

The Centers for Medicare & Medicaid Services (CMS) has begun auditing California physicians who received payments through the federal electronic health record (EHR) incentive programs. Physicians selected for the audit have received letters from CMS contractor Figliozzi and Co., with requests for documentation to support their stage 1 meaningful use attestation. Figliozzi is an accounting firm that specializes in auditing health care facilities for Medicare cost compliance.

Under the 2009 federal economic stimulus package, health care providers can qualify for Medicaid and Medicare incentive payments by demonstrating meaningful use of certified EHR systems. The law also requires CMS to audit health care providers attesting to meaningful use. According to CMS, the audits will impact 5 to 10 percent of physicians who have received incentive payments.

The letters generally request that physicians provide the following information:

  • Evidence that they are using certified EHR technology
  • Their method of reporting emergency department admissions
  • Documentation that the physician completed the attestation module for the core set and menu set objectives and measures.

Physician practices who receive such a letter should consider contacting a Regional Extension Center such as CalHIPSO (www.calhipso.org), their EHR vendor or a consultant for assistance.

For more information on the federal EHR incentive programs and meaningful use, see CMA On-Call documents #4301, "EHR: Federal Incentive Program," #4302 "Meaningful Use of Electronic Health Records (EHRs)." These documents, as well as the rest of CMA's health law library, are available free to members on CMA's website at www.cmanet.org/cma-on-call. Nonmembers can purchase documents for $2 per page.

Contact: Center for Legal Affairs at (800) 786-4262 or legalinfo@cmanet.org