6 Tips for MACRA Changes in 2019

As 2018 nears a close, clinicians should look ahead at evolving Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) regulations and policies. With the new Quality Payment Program (QPP) Year 3 final rule just announced, check out the following six tips for Merit-based Incentive Payment System (MIPS) reporting requirements:

  1. Assess the new rule- Review the official QPP Year 3 final rule fact sheet overview from CMS here to gain a comprehensive summary of category changes and scoring requirements.

  2. Know who is MIPS eligible in Year 3- Physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists and registered dietitians or nutrition professionals have been added for eligibility in MIPS Year 3. This MIPS eligibility list is in addition to the existing participants, including physicians, nurse practitioners, physician assistants, clinical nurse specialists, certified RN anesthetists and groups or virtual groups that include one or more of these clinician types.

  3. See who is exempt from MIPS Year 3 participation- To be exempt from MIPS Year 3 participation, clinicians or groups must meet one of the following three criteria:
    • have $90,000 or less in Part B allowed charges for covered professional services;
    • provide care to 200 or fewer Part B beneficiaries; or
    • provide 200 or fewer covered professional services under the Physician Fee Schedule (PFS).

    The third exemption option is new in MIPS Year 3.

  4. Learn about the new opt-in option- Clinicians or groups who meet the exemption criteria above can opt in to participate in MIPS Year 3 reporting if they meet only one or two low-volume threshold MIPS exemption items (not all three). In 2019, CMS will also allow clinicians based at a healthcare facility to use facility-based scoring to reduce the burden of having to report separately from their facility.

  5. Understand MIPS category changes- The Quality category will account for 45 percent, Cost for 15 percent, Promoting Interoperability (PI) for 25 percent and Improvement Activities (IA) for 15 percent. The overall payment adjustment increases to plus or minus up to seven percent. MIPS wording changes in the Year 3 final rule as well with terms like Collection Type, Submitter Type and Submission Type. CMS says the terminology change better reflects how clinicians and vendors interact with MIPS.

  6. Comprehend MIPS bonus adjustments- In 2019, the small practice bonus (for practices with 15 eligible clinicians or fewer) offers up to six points, but it will only apply to the Quality performance category score, not toward the overall MIPS final score. Also, 2015 CEHRT is required for MIPS Year 3. It is no longer a bonus opportunity. The 2019 final rule eliminates the old PI bonus structure and scoring method to transition focus to performance-based scoring at the individual measure level to tally up to 100 points.

Utilize these six MIPS Year 3 tips to maximize reimbursement for your group or practice as you think ahead for MACRA in 2019. Stay tuned for additional health IT and revenue cycle insight.