MDNews - Cleveland-Akron-Canton

July/August 2017

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PRACTICING MEDICINE IN the current times often requires a substantia l amount of reading to keep up with the regulatory requirements. However, ma ny consumers a re dema nding more va lue from their hea lth care. Through the Centers for Medicare and Medicaid (CMS), the Department of Hea lth & Human Services (HHS) institutes the quality-based programs that tie physician reimbursement to that value. The challenge is that the qua lity program requirements are often di¡cult to interpret and even harder to implement. For ma ny physicia n practices, prog ra ms like Physicia n Qua lity Repor ting System (PQ RS), Mea ning ful Use (MU) and Va lue-Based Payment Modifier (VBPM) began to overlap a nd in some cases conflict. Enter M ACR A . The Medica re Access & CHIP Reauthorization Act of 2015 was voted into law a nd consolidated these progra ms. It a lso replaced the former Sustainable Grow th Rate (SGR) that most physician practices found a n xiet y-provoking each December. With va lue still the goa l, physician practices are a ll now working under one program. Pa r t of the tra nsition to va lue requires a practica l a nd staggered approach away from volume-only reimbursement to reimbursement based on qua lity performances. Merit-Based Incentive Payment System (MIPS) combines these former pro- grams, PQ RS, MU, and VBPM. MIPS is a points-based scoring system and includes four categories: Qua lity (60%), Resource Use/Cost (0%), Clinical Practice Improvement Activities (15%), and Meaning ful Use of Certified EHR Technolog y (25%). Based on a provider's score in these categories, subsequent yea r's Medica re payments a re subject to a 4% adjustment, positive or negative. MIPS is a budget-neutral program, meaning that payment increases will be available only when some eligible providers are subject to a downward or negative adjustment. With each successive year, those potentia l adjustments will increase, a nd by 2022, providers will be at risk for up to a 9% payment adjustment, positive or negative. All billing practitioners in physician practices are eligible and expected to participate in MIPS. Those include physicians, nurse practitioners, and physician assistants. There are only a limited number of exceptions for participation and pertain to insu¡cient Medicare volume, alternative payment model participation and new enrollment in Medicare. Other exempted groups include non-patient facing clinicians such as radiologists or pathologists. A lternative Pay ment Models (A PM's) a re government programs under which physician practices may participate, and in some cases earn a bonus, while taking on some financial risk when their performance does not meet expected goa ls. Each model has specific and typica lly more complex require- ments that tie qua lity to reimbursement. Some examples of an A PM are the Comprehensive Primar y Care Plus (CPC+) initiative, and the Medicare Shared Savings Programs (MSSP). Participation in an A PM is not mandatory but can have some MIPS scoring advantages. While the acronyms continue, the good news is that physician practice reporting is now consolidated under one program, and practices are no longer exposed to the annua l December legislative debate under the SGR and the associated Medicare Physician Fee Schedule impacts. NOTE: This article is intended to provide an overview of the law and not intended to provide legal or other guidance. Daniel Glessner is Co- Chair, Brouse McDowell Practice G roup, and Nicole Thorne is Law Clerk, Brouse McDowell, in Akron, OH. ■ BY DANIEL K. GLESSNER, CHC, AND NICOLE THORNE VOLUME TO VALUE: The Physician Practice's Alphabet Soup $ 2 4

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