The reporting year 2017 has not changed from the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) proposed ruling, but there are many recent changes to reporting requirements to consider. Instead of the “all in” proposed reporting requirement, the final rule now allows eligible clinicians to choose from three flexible Merit-based Incentive Payment System (MIPS) reporting options as well a fourth Advanced Alternative Payment Model (AAPM) option. Moreover, all eligible clinicians must participate in one of the reporting options or they will be subject to the full negative four percent payment adjustment in 2019 based on the 2017 performance year.
These options can be summarized as follows:
Reporting Option 1 – Test Run
The first reporting option gives eligible clinicians a chance to adjust to the new MIPS program. Under this option, participants are required to report one quality measure, one activity from the Clinical Practice Improvement Activities performance category, or five of the eleven Advancing Care Information measures. This option does not qualify for a payment adjustment incentive for participation.
Reporting Option 2 – Limited Participation
The second reporting option requires eligible clinicians to report more than one quality measure, more than one Clinical Practice Improvement Activities measure, or five measures in the Advancing Care Information category. Under this option, clinicians are not subject to a penalty but can earn a nominal adjustment incentive.
Reporting Option 3 – Full Participation
The third reporting option requires eligible clinicians to report all required measures for a consecutive 90-day period, or ideally, a full calendar year. Participants with a MIPS Composite Performance Score (CPS) above 70 in year one (2017) are eligible for an additional exceptional performance bonus. This option presents the possibility of earning the maximum adjustment incentive plus a share of the $500,000,000 exceptional performance bonus allocation.
Reporting Option 4 – Advanced APM Participation
MIPS eligible clinicians who participate in an AAPM are deemed a Qualify Participant (QP) by meeting the required thresholds for the number of patient encounters or the Medicare payment volume via the AAPM and/or the particular measures and objectives of the AAPM. In 2019, QP’s will be awarded a payment equal to five percent of the clinician’s 2018 Part B payments.
Although the MACRA rule is final, CMS explained that the program will continue to “evolve over multiple years in order to achieve our national goals." As you continue to navigate MACRA, we encourage you to take advantage of our MACRA educational webinar series. We also hope you will take advantage of our free MACRA readiness assessment. Let us help you reach MACRA success!
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