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
Out of four categories, you would need to submit information for the year on Quality and Improvement Activities. For Quality, you would want to capture and report on six quality measures, including an outcome measure. You would also attest that you completed at least two Improvement activities. Advancing Care Information and Cost are items that you wouldn't need to address this year.
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.
For more details about MACRA requirements, join us for the upcoming webinar "MACRA and Hospitalists — Are You Prepared?" on April 20, 2017 at 2pm ET and get your questions answered.