MACRA Year 2: Final Ruling
As the Quality Payment Program of the Medicare Access and CHIP Reauthorization Act of 2015 enters into the second year, practitioners need to know what the Final Rule for The Quality Payment Program Year 2 requires. This year is another year of transition to help participants in the program get accustomed to the guidelines.
The QPP includes two programs, the Merit-based Incentive Payment System and the Advanced Alternative Payments Model. Together, these programs reward practitioners who take the time to ensure patients get a high quality of care instead of placing the focus on paperwork or just shuttling patients through a fee-based system of care.
As part of the paperwork reduction component, which is known as Patients Over Paperwork, there are some initiatives that are in place for Year 2. Here are a few of these:
- MIPS eligible practitioners can form into groups under the program. If these groups or individual clinicians have $90,000 or less in Part B-allowed charges or have 200 or fewer beneficiaries of Part B, they are excluded from the requirements.
- The number of required performance points was raised from three in Year 1 to 15 in Year 2. Clinicians who treat complex patients earn five bonus points and small practices can also earn five bonus points.
- Incentive payment qualifications for Advanced APMs can start and stop in the middle of the year.
- The rule for groups is that clinicians can form groups of 15 or fewer individuals for the purpose of gaining points toward higher incentive payments. This will make it easier for some smaller practices to reach the Year 2 performance threshold of 15 points.
- Natural disasters and other uncontrollable and extreme circumstances are addressed for this year and the performance period for 2018. The weight of Quality, Advancing Care Information, and Improvement Activities will be set to 0 percent for clinicians who are impacted by these.
- Cost is now going to be weighted to 10 percent of the final score.
- Advancing Care Information standards for Year 2 allow clinicians to use CEHRT 2014, 2015, or a combination of both. Bonus points are awarded to clinicians who use only CEHRT 2015 software and programs.
What all of this means for clinicians
One of the new changes for Year 2 requires clinicians to meet a higher minimum point threshold. Last year, the threshold was only three points. Year 2 is 15 points. Clinicians who don’t meet that threshold face a negative adjustment to their incentive payments, which means less money for the practice.
Because smaller practices might find the reporting requirements of the program to be too burdensome, which could mean a negative impact on patient care, groups are being allowed. Clinicians can join a virtual group, which isn’t limited by specialty or location. The limits for this include that there are two or more Taxpayer Identification Numbers in the virtual group and that it is made up of groups of 10 or fewer clinicians or solo practitioners. The virtual group will last the entirety of Year 2 and allows participants to combine their respective points to meet the threshold for Year 2 as a group.
Clinicians who are impacted by natural disasters, such as Hurricane Irma, won’t have to worry about a negative adjustment because of a lack of reporting.
Where Advanced APMs are concerned, Year 2 is also a year of transition and growth. Clinicians will have to determine what APMs they qualify for. These run the gamut from specific patient demographics to specific conditions and types of conditions. The reporting of the information in Year 2 can impact the incentives for Year 3.
Plans to incentivize clinicians who are participating in APMs besides the Medicare system will begin in 2019. This means that practitioners should ensure they are reporting the activities that qualify for the Advanced APMs they are targeting in the QPP.
Overall, the Year 2 Final Rule is providing practitioners a chance to focus on providing high-quality patient care while limiting the amount of reporting that is necessary to comply with the program. This is a good start and a chance to adjust the clinician’s procedures for the following year.