CMS is attempting to lower the burden of the Quality Payment Program (QPP) for small practices and other clinicians, with a proposed rule that would update the physician payment programs created as a part of the Medicare Access and CHIP Reauthorization Act (MACRA). The changes could be important for hospitals and health systems with affiliated physician practices.
The rule would delay certain requirements of the programs for a year and either exempt some providers from participation or provide more flexibility for eligible providers to meet QPP requirements.
The administrative burden is an unfortunate consequence of the QPP initiative that allows providers to choose from the Advanced Alternative Payment Models (APM) or the Merit-based Incentive Payment System (MIPS). The system replaces Medicare Meaningful Use, the Physician Quality Reporting System, and the Value-based Payment Modifier.
Under the proposal, CMS would exclude eligible clinicians who bill less than $90,000 in Medicare Part B charges or who see fewer than 200 Part B beneficiaries. That is substantially different from the 2017 low-volume thresholds of less than $30,000 in Part B charges or fewer than 100 Part B beneficiaries.
CMS is responding to protests from the healthcare industry that Matthew Amodeo, JD, partner with the Drinker Biddle law firm in Albany NY. Physicians were happy to be rid of the sustainable growth rate formula that was replaced by the QPP initiative, but many found the MIPS reporting overwhelming, he says.
“It’s a very big hardship on small practices to do this reporting, and also for rural practices which tend to coincidentally be smaller, but they also have patient populations that are sicker and costlier. They tend to have more chronic conditions, more comorbidities, limitations on their access to the case, so it’s challenging to these physicians already on a cost basis,” Amodeo says. “They have high demands on their time from these patient encounters, so these additional reporting burdens on top of that can have a real impact. It’s administratively a burden and cost-wise too much of a burden.”
CMS responded by changing the requirements so that about another 135,000 physicians would be exempt from compliance, Amodeo says, and about half of those are from small practices. That brings the total number of exempt physicians in the country to about 835,000, he says.
CMS also has proposed keeping the cost portion of the total score at a 0% weight for 2018 reporting instead of increasing it to 10% weight as originally planned.
The physician also would still be able to use 2014 Edition Certified Electronic Health Record Technology (CEHRT) for the 2018 performance year instead of moving to the 2015 edition.
“CMS is becoming much more responsive to industry input, much more flexible, and reacting to what is really happening in healthcare on a day-to-day basis,” Amodeo says. “This is good evidence of that.”
- Matthew Amodeo, JD, Partner, Drinker Biddle, Albany NY. Telephone: (518) 862-7468. Email: firstname.lastname@example.org.