Making Sense of MACRA

Mar 07, 2018 at 03:09 pm by Staff


Develop a Plan to Address Updates for 2018 Reporting

The Medicare Access and Chip Reauthorization Act (MACRA) was signed into law in 2016. Less than a year later, clinicians were expected to begin reporting. During the transition year (2017), the Centers for Medicare and Medicaid Services (CMS) allowed eligible clinicians to "pick their pace" for reporting into the quality payment program (QPP). Now, for 2018, clinicians must provide a full year of reporting on these measures. To add another layer of complexity, CMS has released new changes and updates for this year. An action plan put in place sooner, rather than later, can help ensure proper reporting.


Changes for 2018

Small Practice Relief

For small practices (groups of 15 or fewer clinicians), changes for 2018 could bring about some relief from the previous reporting requirements.

Practice Management Tip: Whether your practice has decided to report as a group or as individual clinicians, be sure to check all clinician eligibility through the MIPS Participation Status (qpp.cms.gov/participation-lookup) site to confirm if the clinicians in your practice are required to submit data to MIPS each year.


Performance Category Updates

As CMS moves towards full implementation of the QPP, many of the transition-year policies have been extended to allow for gradual implementation and further prepare clinicians for full implementation in 2019.

Practice Management Tip: There is no specific information available to the public related to CEHRT requirements for the 2019 performance year and beyond. However, one could surmise that it may become required in the future. Thus, it is recommended that practice administrators and clinicians proactively consult with their technology teams to map out a course for 2015 CEHRT integration. These types of transitions can be more difficult to schedule (and end up being costlier) when performed after a requirement is announced.


Hardships & Exemptions

For the 2017 transition year, CMS allowed for the exemptions of extreme and uncontrollable circumstances, including natural disasters and public health emergencies. Unfortunately, numerous clinicians were affected in 2017. As a result, CMS has extended the application for both the transition year and the 2018 reporting year.

Practice Management Tip: Clinicians who qualify can apply for a hardship exemption by visiting qpp.cms.gov. Applications may still be submitted for reporting year 2017 through March 31, 2018. Applications for 2018 will be available once the 2017 submission period has closed.


Exclusions

Clinicians who may not meet the requirements for reporting ePrescribing and Health Information Exchange (HIE) measures can still qualify for the 2017 exclusion established by CMS.


Action Plan 2018

For many eligible clinicians, 2018 will be the first year of full reporting. To ensure the highest incentive potentials, it's essential for practices to develop an action plan to meet CMS requirements. Some proactive steps to consider for 2018:

As clinicians are working on reporting for 2018, it is imperative that practices and facilities continue to educate personnel on the changes handed down from CMS, as additional alterations are expected in the months and years to come.


Feedback & Comments

Even though the compliance process can feel cumbersome, CMS is considering feedback and comments from clinicians, advisors, and vendors relating to the practicality of reporting requirements under these new rules. The changes relating to small practice relief, performance category adjustments, and hardship exclusions are just a few examples of how feedback is impacting the QPP.

There's no time better than now to have an internal conversation about your reporting requirements to ensure you have a plan in place for 2018. Make sure you have an educated team and the appropriate tools and procedures in place to achieve the maximum possible score for your clinicians and practice.


Jessica Benson, CPA, a supervisor on the KraftCPAs healthcare industry team, has more than nine years of experience in public accounting. Danielle Tribout, CPC, CPMA, CEMC, a coding and compliance consultant with Kraft Healthcare Consulting, has more than 12 years of experience in the healthcare industry. For more information, go online to kraftcpas.com.




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Tags: CEHRT Danielle Tribout ePrescribing Jessica Benson Kraft Healthcare Consulting KraftCPAs MACRA Medicare Access and CHIP Reauthorization Act Merit-based Incentive Payment System MIPS Physician Reimbursement QPP Quality Payment Program
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