I understand hospitals are trying to digest information about hospital-based physicians based on the latest information from The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Let's take a look at the questions we need to ask. Do you need to participate in Quality Payment Program (QPP)? Do you need to participate in Merit-based Incentive Payment System (MIPS)? The answer is yes to both!
So who Isn’t Eligible?
- Clinicians who enroll for Medicare for the first time during the MIPS performance period are exempt from reporting until the following year.
- Clinicians who have less than or equal to $30,000 in Medicare charges or fewer than 100 Medicare part B patients per year.
Who IS Eligible?
- Clinicians who furnish 75% or more of their professional services in POS 21, 22, and 23 or inpatient, campus outpatient hospital, or emergency room setting.
The determination for the hospital-based designation is done individually, at the individual NPI level, even if the Tax ID is choosing to submit for MIPS as a group. This is because there is no separate definition for a hospital-based group for MIPS.
Now that you have considered if your hospital-based physician is eligible, you then have to decide what you need to submit to make certain you bolster the organizational coffer or get the best chance of a 4% positive payment adjustment for 2019.
Submit for Positive Payment Adjustment
QPP has four categories —
- Improvement Activites
- Advancing Care Information
If this seems like too much for the transition year (2017), submitting one Improvement Activity and/or one Quality Measure to avoid a downward payment adjustment might be the best option for you.
CMS has done a significant amount of work trying to make things clear on their website. Check it out at http://qpp.cms.gov.