TSI Healthcare Top 10: MACRA FAQ

Meagan
Meaningful Use &
Clinical Quality Specialist

The Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) is confusing, we get it. As part of
TSI Healthcare’s ongoing commitment to providing you with the most current information on MACRA, we have compiled a list of Frequently Asked Questions (FAQ). Take a look below to find the answers to your MACRA questions. Before you begin, follow the links below for an in-depth look at MACRA through our blog series, MACRA: Navigating the Final Rule, dedicated exclusively to helping you navigate the murky waters of government regulations.

  1. Key Changes Your Practice Will Face During the 2017 Performance Period of the New Quality Payment Program
  2. Proposed Rule Versus Final Rule: MIPS Composite Performance Scoring
  3. 5 Steps to Prepare for MACRA
  4. MACRA Special Considerations for Small Practices

TSI Healthcare Top 10: MACRA FAQ

Penalties and Incentives in MACRA

1. Q: Does the payment adjustment follow a provider or does it stay with the practice?

A: The penalty and bonus will follow the provider if they transition from one practice to another. In fact, similar to Meaningful Use, CMS is expected to create a website where you can view your MIPS payment adjustments and feedback reports.

2. Q: How will my practice’s incentive be impacted if we participate on different levels for 2017?
A: If you chose not to submit ay data for the 2017 transition year, you will be automatically penalized at a negative 4% payment adjustment. If you submit any data (test option) to CMS for the 2017 transition year, you will not receive a penalty or a bonus. Finally, if you submit for a partial or a full-year, you are eligible to receive a 4% positive payment adjustment, with the opportunity to earn more.

Reporting for MACRA

3. Q: If my practice is currently reporting as a Group Practice Reporting Option (GPRO), will we need to continue reporting as a GPRO in 2017?
A: Due to MACRA’s flexibility, you do not have to continue reporting as a group in 2017 if you do not wish to do so.

4. Q: My practice has a new provider. Are they exempt from this program, or do they need to report in 2017?
A: There are only three ways that a provider can be exempt. If the provider does not meet one of these three exemptions, then they will need to submit data in 2017. The three exemptions are below:

  1. New Medicare Providers – 2017 is the first year they submit a Medicare Part B claim
  2. Low-Threshold Providers – The provider sees less than 100 patients or bills less than $30,000 in Medicare Part B claims in a year
  3. Advanced APM Participant

5. Q: Will there be an attestation process through CMS for 2017?
A: Due to the increased flexibility options MACRA provides, there will be a few different submission options. Your practice will be able to submit data through a variety of different methods, including an attestation website, a qualified registry such as NextGen’s HQM module, or a Qualified Clinical Data Registry, such as Rise for Rheumatology or IRIS for ophthalmology. Health IT vendors, such as NextGen, are also able to report your data through EHR submission. It’s important to keep in mind that however your practice chooses to submit its data, all data must be submitted appropriately. For example, all of your Quality data must be submitted through one method. Ultimately, your practice can mix and match submission mechanisms between categories, but all data must be submitted via one method for each category.

6. Q: Can you explain data completeness for MACRA attestation further?
A: Previously for the Physician Quality Reporting System (PQRS), your practice was required to turn in data for 50% of your Medicare part B patients. If your practice was doing registry reporting, at least 50% of your Medicare Part B patients needed to be included in your PQRS submission.

TSI Tip: TSI Healthcare will submit data for 100% of your patients. This is possible because we are able to pull all of the data from your PM and EHR. For 2017 MIPS, the data completeness threshold will stay at 50% but will be expanded to include all patients, not just patients with Medicare Part B insurance. In 2018, the data completeness threshold will increase to 60% of all patients seen by the MIPS Eligible Clinician (EC).

Advancing Care Information (ACI) Category

7. Q: If the new ACI category is replacing Meaningful Use in 2017, can Meaningful Use be reported on as a group?
A: Yes. The new model streamlines reporting options for practices. One of these streamlined items will allow practices to submit as a GPRO for all items and not just PQRS.

8. Q: How does reporting for the ACI category work with the eight different objectives?
A: Each of the eight different objectives have 1-3 measures within them. Four of the objectives are a part of the base score and are required to be reported to receive any credit for the ACI category. Out of 100% for the category, the base score will earn you 50%. Practices earn the additional 50% through their performance score. The performance score consists of seven additional measures that practices can choose to report.

Improvement Activities Category

9. Q: My practice is very small. Do we still need to submit 40 points for the Improvement Activities category or does the number of points reduce?
A: CMS has enacted several special considerations for small practices, including the number of required points for the Improvement Activities category. Practices with 15 or fewer practitioners, located in rural areas and health professional shortage areas (HSPAs), will only be required to submit half the amount of required activities in order to receive full credit. Small practices receive double credit for the Improvement Activities they complete, so though you do need to reach 40 points, it is easier for you to get there.

TSI Tip: As part of TSI Healthcare’s commitment to providing its clients the latest information on MACRA, we have created a blog series dedicated exclusively to helping you navigate MACRA. Click here to view the full list of 2017 small practice considerations.

Cost Category

10. Q: If a patient sees my practice more than their primary care provider, are they attributed to us for the cost category?
A: If a patient sees a primary care provider at least once during the performance period, they will be attributed to that provider. Specialty providers will only be attributed to a patient if that patient did not see any primary care physicians during the year.

TSI Tip: The QRUR report is a Quality and Resources Use report which outlines how much your practice costs or saves the system. If your practice has not seen a QRUR report, you should download the report and begin analyzing the information. This report also shows which patients in the past have been attributed to you. A bi-annual analysis of this report will be part of our new Quality Program Services.

 

Need more help navigating MACRA? Watch our webinar “MACRA101: The New Quality Payment Program,” to learn more about the new federal policy changes.

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