Although there has been significant concern regarding clinicians’ readiness for MACRA/MIPS, the Centers for Medicare & Medicaid Services (CMS) has said that for varying reasons, many Medicare doctors won’t have to report to the Merit-based Incentive Payment System (MIPS) this year.
MACRA’s (the Medicare Access and CHIP Reauthorization Act of 2015) Quality Payment Program (QPP) includes two payment paths that eligible Medicare-participating physicians could partake in—MIPS and the advanced alternative payment models (APM) track. While the MIPS path involves more data reporting on the part of doctors, it comes with less risk for losing money; for each reporting year of the program, eligible clinicians are given a MIPS score which determines their Medicare payment adjustments two calendar years later.
Indeed, since MIPS is the less risky track for doctors, it was estimated by CMS officials back when the MACRA final rule came out last October that just 5 to 8 percent of participating clinicians would be in the advanced APM track. Meanwhile, as Healthcare Informatics Senior Contributing Editor David Raths reported last fall, “CMS estimates that more than half of all clinicians will be excluded from MIPS. The largest excluded cohort, 32.5 percent, or over 380,000, will not meet the low-volume threshold, which includes clinicians with $30,000 or less in Medicare Part B allowed charges or less than 100 Medicare patients.”
But that “more than half” estimate from CMS has now been increased to some two-thirds of clinicians who will be exempt from MIPS. In addition to the low-volume Medicare physicians, and the ones who will be participating in the advanced APM track, there is another bucket of doctors who can bypass MIPS as well, according to CMS. In the feds’ QPP summary from October, they wrote, “We estimate that nearly 200,000 clinicians, or approximately 14.4 percent, are not one of the eligible types of clinicians for the transition year CY 2017 of MIPS under section 1848(q)(1)(C).” This section of MACRA states that “in the case of a professional who becomes a Medicare-eligible clinician during the performance period for a year (and has not submitted claims to Medicare previously), the eligible clinician will not be treated as a MIPS eligible clinician until the subsequent year and performance period for that year.”
In sum, a CMS spokesperson confirmed to Healthcare Informatics (but was first reported by other healthcare publications) that in terms of the number of clinicians, “418,849 will receive notification that they are participating in MIPS, while 806,879 will be notified that they are not participating in MIPS.” Of course, however, the CMS source noted that the number of clinicians participating in MIPS “represents MIPS participation only and does not include those that will participate through MIPS alternative payment models or advanced APMs. When considering MIPS APMs and/or advanced APMs, as well as practices that choose to participate in MIPS as a group, the number of total participants will be higher,” the spokesperson stated.
As such, CMS has mailed approximately 280,000 letters to practices using the Taxypayer Identification Number (TIN). The letter includes the MIPS participation status of each clinician associated with that practice’s TIN, according to the agency’s spokesperson.
For many Medicare clinicians, in addition to the fact that 2017 was already declared a year of transition and flexibility for MACRA—with 2018 possibly following along the same lines—the news that they will be exempt from MIPS in year one of the program will be a welcomed relief. For one, many smaller practices without the resources to report and comply will potentially save a significant amount of money by not partaking. What’s more, many MACRA participants will now be afforded more time to figure out how much money they might earn or lose in the program; a recent Black Book survey revealed that nearly 90 percent of responding physicians had no idea how to calculate their MACRA earning potential.
What’s more, in its comments to Healthcare Informatics, CMS noted a third track for MACRA’s QPP, the MIPS-APM track, which has not gotten much press to date. Regarding this track, as a recent brief from Charlotte, N.C.-based Premier Inc. pointed, out, not many people, including physicians and health system leaders, know about this QPP path that simplifies reporting and has less downside risk. As Premier stated in its brief, “The MIPS-APM track provides incentives for a movement toward population health for organizations that are not prepared to assume the downside actuarial risk required to qualify for an Advanced APM. An example of a MIPS-APM with no downside risk is Track 1 of the Medicare Shared Savings Program (MSSP).”
Premier continued, “This is important and timely information for those that aren’t aware. While technically still considered part of the MIPS program for the purposes of the QPP, MIPS-APMs reduce the administrative burden, qualify for preferential scoring, present no downside risk, and participants in a MSSP Track 1 ACO are able to reap all the benefits of a Medicare ACO program (like earning shared savings and accessing claims data). Basically, MSSP ACO participants will likely perform better under MACRA. So, providers not already in the MSSP program should definitely think about joining, and even if they’re on the fence, they should send a nonbinding notice of intent to apply to the program ASAP.”