South Florida Hospital News
Sunday April 21, 2019
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March 2019 - Volume 15 - Issue 9

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MACRA – Is Your Medical Practice Poised for Success?

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is a bipartisan legislation signed into law on April 16, 2015. Administered by Centers for Medicare and Medicaid Services (CMS), this law created the Quality Payment Program (QPP) that: repeals the Sustainable Growth Rate (SGR) formula, changes the way that Medicare rewards clinicians for value over volume and streamlines multiple quality programs - Physician Quality Reporting System (PQRS), Meaningful Use (MU), and the Value Modifier (VM) programs. It also required the removal of Social Security Numbers (SSNs) from all Medicare cards by April 2019.

The Bottom Line
About 30% of medical practices’ panels are Medicare patients according to the AMA 2016 Physician Practice Benchmark Survey. Given an increasing healthcare market share of baby boomers, the ever shrinking reimbursements, and a seemingly irreversible healthcare embrace of value based and pay-for-performance programs, the mandated QPP has considerable impact on the viability and sustainability of medical practices and providers.
 
Quick Participation Preferred:
The QPP which is in its 3rd performance year and 1st payment adjustment year has two tracks: Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM).
 
MIPS payment adjustments are based on your performance on the measure and activity data you collect and submit for four MIPS performance categories: Quality, Improvement Activities, Promoting Interoperability (through the use of certified EHR technology) and Cost. Each category is worth certain percentage and within it, each measure carries points. After taking into account the set minimum threshold, the final cumulative score is used to determine whether you receive a positive, neutral, or negative payment adjustment on your Medicare Physician Fee Schedule (PFS) and Medicare Part B allowed charges. Since QPP must remain budget neutral, the amount by which a positive MIPS payment adjustment factor is increased or decreased depends on the distribution of final scores across all MIPS-eligible clinicians.
 
APM gives added incentive payments to provide high-quality and cost-efficient care by way of bonus payments for participation in an eligible alternative payment models (APMs) such as the various ACOs, bundling, and shared savings programs. CMS determines the qualifying APM participants (QPs).
To check your eligibility for participation by performance year, use the QPP participation status tool that can be found on the CMS – QPP website by entering your 10-digit National Provider Identifier (NPI) number to find out about your requirement to participate or even if you can opt-in. 

The submission window for the performance year in 2018 is open through April 2, 2019. CMS web interface users need to report their quality performance category data by March 22, 2019.   If you are a clinician/practice that reported quality measures via Medicare Part B claims throughout the 2018 performance year, CMS receives your quality data from claims processed by your Medicare Administrative Contractor (MAC). Claims for services provided during 2018 must be processed within 60 days after the end of the 2018 performance period. If you are submitting data through your electronic health record (EHR) or a Registry/Qualified Clinical Data Registry (QCDR), abide by your internal submission dates. 
 
What the Future Holds
The current full performance period is January – December 31, 2019, but not all categories require 12 months of data collection. Payment adjustments based on this performance period will be made in 2021. By law, this program must be administered and though it may be modified from year to year, it is here to stay. The program continues to evolve given the underlying pressure to drive value over volume, and identify meaningful patient outcomes while reducing the burden on providers.  
 
Success is Paramount
Success with QPP really hinges on the basics of proper planning and monitoring. First, visit the CMS- QPP website to determine participation eligibility and the measure requirements for your practice. Set up the reporting mechanisms and reports –technology is vital for this. Review your performance against set goals on a monthly basis, and make indicated improvements accordingly. Ensure that you manage activities to all deadlines.
 
There are many ways for medical practices to get assistance with facilitating a successful implementation of QPP. Practice transformation consultants are available to assist with the full implementation of the program in your respective practices and, direct technical assistance are available on the CMS-QPP website.  Success in the MACRA-legislated QPP program is now a key business imperative for healthcare providers. For information about the QPP program, visit the CMS website at https://qpp.cms.gov/
 
 

Oyinkansola Ogunrinde is the Founder and Chief Practice Transformation Officer of FUNMI Healthcare Consulting, LLC, a consultancy specializing in the management of physician practice and ambulatory services (www.funmihc.com). She can be reached at bukky@funmihc.com and (561) 320-1071.

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