The Medical Group Management Association (MGMA) in a letter sent Wednesday to CMS asked the agency to immediately notify clinicians and group practices of whether they are exempt from certain MACRA requirements.
Under MACRA's Quality Payment Program (QPP), eligible professionals can choose from two payment tracks:
- The Advanced Alternative Payment Model (APM) track, for clinicians who take on a significant portfolio of Advanced APMs, which include risk-based ACO models; or
- The Merit-based Incentive Payment System (MIPS), for providers who are reimbursed largely through fee-for-service.
Eligible providers who participate in MIPS beginning in 2019 will be able receive penalties or bonuses of up to 4 percent. That percentage will rise incrementally until it reaches 9 percent in 2022.
Eligible providers subject to the requirements are:
- Certified registered nurse anesthetists;
- Clinical nurses specialists;
- Nurse practitioners;
- Physicians; and
- Physician assistants.
CMS has estimated that the new payment models affect more than 600,000 eligible professionals. Eligible professionals include those who bill Medicare for more than $30,000 or care for more than 100 Medicare beneficiaries annually.
CMS said 2017 is a "transition" year for the program. Providers who were ready to begin participating in the programs could start collecting performance data on Jan. 1. Providers who are not yet prepared to participate have until Oct. 2 to begin collecting performance data. Participating providers must submit all data, regardless of when collection began, to CMS by March 31, 2018.
MGMA urges CMS to send eligibility info
According to MGMA, CMS has estimated that 32.5 percent of Medicare providers are exempt from MIPS this year under MACRA's "low volume threshold." They wrote that CMS had said it would issue in December 2016 eligibility notices to providers subject to MIPS' requirements.
But no such notification has occurred, MGMA wrote. They noted that it currently is "three months into the 2017 performance period" and "CMS has failed to notify clinicians and group practices regarding low volume threshold exemptions, status as hospital-based or non-patient-facing, as well as approved lists of [data] registry vendors" under MIPS. The group wrote that the delay "is generating considerable frustration and confusion" among providers.
MGMA wrote that "without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in" MIPS. In addition, the group stated that "the absences of a final list of approved 2017 qualified registries and qualified clinical data registries" is "further hindering group practices' success in MIPS."MGMA wrote that CMS' failure to notify clinicians and group practices of their status as hospital-based or non-patient facing" prevents them from knowing the rules under which they must comply.
"We urge CMS to expeditiously release these long overdue MIPS eligibility notices and approved vendor lists," MGMA concluded.
According to Modern Healthcare, a CMS spokesperson did not say why CMS missed its December 2016 deadline to send the notifications, but said the agency plans to send the notifications this spring (Morse, Healthcare Finance News, 3/15; MGMA letter, 3/15; Morse, Healthcare IT News, 3/16; Dickson, Modern Healthcare, 3/16).
Rethinking your Medicare risk strategy under MACRA
MACRA is forcing groups to reevaluate their participation in alternative payment models. While the 5 percent bonus for the Advanced Alternative Payment Track of MACRA is appealing, taking on risk isn't a decision medical groups should take lightly.
Join Advisory Board’s Ingrid Lund on Thursday, March 30, to discuss the benefits of taking on risk under MACRA and learn how to determine the right model and amount of risk your group should take on to be successful.