Physician Data Analytics and Your EHR – Impact of MACRA, MIPS, and SGRs (Part 3 of 3)

Medical Lawsuit

By Richard Howe, PhD, Executive Director, North Texas Regional Extension Center

Last month, I discussed more about how the Merit-Based Incentive Payment System (MIPS) for physicians, Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VBPM) and meaningful use (MU) will become integrated into a single program. The MIPS program is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation, which repealed the sustainable growth rate (SGR) formula.

So, how can I as a provider be exempt from participating in the MIPS program?

The answer is simple: providers must participate in either MIPS or in value-based Alternative Payment Models (APMs). Providers who participate significantly in APMs may be exempt from the four performance measures in the MIPS program (see last month). Professionals who receive a significant share of their revenues through an APM that involves risk of financial losses and a quality measurement component will receive a 5% bonus each year from 2019-2024. These bonuses are larger than what is available in MIPS and a physician cannot participate in both MIPS and APMs.

Accountable care organizations and medical homes are examples of APMs. An APM taking the form of a medical home does not have to satisfy the financial risk requirement “if proven to work in the Medicare population,” according to the lawmakers’ summary of the bill.

So, how does the MACRA legislation help small practices?

On page 59103, under Section C entitled “Technical Assistance to Small Practices and Practices in Health Professional Shortage Areas,” the MIPS regulation states that the CMS Secretary is required “to enter into contracts or agreements with appropriate entities to offer guidance and assistance to MIPS EPs in practices of 15 or fewer professionals.” Appropriate entities include Quality Improvement Organizations (QIOs), Regional Extension Centers (RECs) as described in section 3012(c) of the Public Health Service Act (PHSA), or regional health collaboratives.

The law allocates $100 million ($20 million per year) for the U.S. Department of Health and Human Services to support organizations (QIOs, RECs) that provide technical assistance to practices with 15 or fewer eligible professionals participating in an APM or the MIPS. Priority will be given to practices in rural areas, health professional shortage areas, and medically underserved areas, and to practices with low composite scores. The allocated money will not fund changes at the individual practice level.

At this point, MACRA can be viewed as either a boon or a bust to your practice and just another piece of regulation that you must adhere to. With proper planning, this is an opportunity to grow your practice, increase revenue and improve patient care at the same time. Are you in and — are you ready?