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MGMA Urges CMS to Immediately Release MIPS Reporting Information

March 16, 2017
by Rajiv Leventhal
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“Providers have been left in the dark,” the healthcare association stated

In a letter to the Centers for Medicare & Medicaid Services (CMS), the Medical Group Management Association (MGMA) has called for the immediate release of critical 2017 Merit-Based Incentive Payment System (MIPS) eligibility information, including notifications about the low volume threshold exemption.

Now three months into the 2017 reporting period for MIPS—one of two payment paths eligible Medicare clinicians can take under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA’s) Quality Payment Program (and the far more likely path for most participants)—MGMA said that 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 registry vendors.”

MGMA and its 50 state affiliates comprise more than 33,000 administrators and executives in 18,000 healthcare organizations in which 385,000 physicians practice, the Englewood, Colo.-based organization says.

Per the MACRA final rule, clinicians and group practices that fall under the low-volume threshold, because they bill $30,000 or less in Medicare charges or furnish care to 100 or fewer Medicare beneficiaries, are exempt from MIPS. CMS estimated nearly one-third of eligible clinicians would be exempt from MIPS in 2017 under the low volume threshold. But as MGMA has pointed out in the letter to recently-confirmed CMS Administrator Seema Verma, “Yet three months into the 2017 performance period, CMS has left these providers in the dark about whether they must comply with program criteria. In addition, CMS has failed to notify clinicians and group practices about their hospital-based or non-patient facing status, which carry modified reporting requirements.”

The letter continued, “Transitioning to MIPS is a challenge involving upgrades to electronic health record software, re-engineering clinical workflows to meet data capture and reporting requirements, contracting with data registries, and training clinical and administrative staff. Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program.”

What’s more, MGMA noted that “Further hindering group practices’ success in MIPS is the absence of a final list of approved 2017 qualified registries and qualified clinical data registries. Group practices planning to utilize these reporting mechanisms must either delay engagement or partner with vendors without a guarantee they meet CMS’ qualifications. We urge CMS to expeditiously release these long overdue MIPS eligibility notices and approved vendor lists.”

Overall, there has not been much conversation around the MACRA program yet in 2017, despite this being the first reporting year for eligible Medicare clinicians. This could be due to the transition that has taken place inside CMS and HHS, with new leaders having recently taken over these agencies under the Trump administration.

Verma has commented on how MACRA could be a big challenge for smaller physician practices, noting in a Senate hearing last month that “it’s a worthy goal” and “we have to support them.” She added, “For smaller providers taking risk, they will be reluctant since they don’t have the financial reserves that bigger health systems have. When thinking about holding providers accountable for outcomes, that also depends on patients. So we need to think about strategies for engaging patients so they can work with providers for achieving outcomes. Smaller and rural providers taking on risk will be a formidable challenge.”

In an effort to help these practices, last month, CMS affirmed the awarding of approximately $20 million to 11 organizations for the first year of a five-year program to provide on-the-ground training and education about the Quality Payment Program. CMS said in the announcement that it intends to invest up to an additional $80 million over the remaining four years.

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