Still in the works: Determining real-time eligibility.
This article first appeared February 14, 2018 on Medpage Today.
By Shannon Firth
WASHINGTON -- Physicians who are anxious about year 2 of the Merit-based Incentive Payment System (MIPS) got some relief from a Centers for Medicare and Medicaid Services (CMS) official, but some of the agency's answers were still pretty fuzzy.
"We'd like to get to a place where we can determine real-time eligibility, but we're not there yet," said Kate Goodrich, MD, MHS, director and chief medical officer for the Center for Clinical Standards and Quality at CMS, at the American Medical Association National Advocacy Conference here.
"We understand people need to plan ... make business decisions if [they're] eligible," she added.
MedPage Today recently reported on clinician complaints that they can't tell whether they are part of the MIPS program.
Under the Medicare Access and CHIP Reauthorization Act (MACRA), physicians would be notified about their MIPS eligibility prior to the performance year in which they are being measured. Quality reporting began on Jan. 1, 2018.
The agency wants providers to visit its website, and enter their national provider identifier (NPI). Eligibility determinations will be available through the 2018 NPI look-up tool "very very soon, certainly by the end of the first quarter" Goodrich said.
Asked whether clinicians excluded from MIPS because of the low-volume threshold would still be able to join, Goodrich said the agency is working on that.
Because of the way the law is written, a "pure opt-in" option, where CMS says "any of you can participate if you want," is simply not possible, she explained. However, CMS is working with its lawyers to identify a mechanism to allow providers who are below the low-volume threshold to opt-in.
Goodrich explained that there are three ways to determine the low-volume threshold:
- Number of Medicare patients
- Amount of Part B revenue
- Number of Part B items and services
This last component has yet to be tapped, but if CMS chooses to incorporate it, those who fall above any one of those three thresholds will be allowed participate.
Goodrich conceded that the approach was complicated. "We are going to need help from you in figuring that out," she told attendees.
Asked if CMS had plans to simplify MIPS, Goodrich laughed nervously and replied "Yes." For example, the agency is looking to find places where quality, advancing care information, and improvement activities -- three of the four measurement categories -- could be better aligned.
"So, you're telling us essentially about one or two things that you're doing, but because of the way they're constructed, and because they're actually relevant for your practice, they would count for all three categories. So that would mean you wouldn't necessarily have to report to all three," she said.
But "Getting there for every single specialty type is going to take time," she cautioned.
Asked whether the agency would allow practices to submit 90-days worth of data, rather than a full-year if there are disruptions to their practice -- such as an electronic health records (EHR) system going offline or a change in EHR vendor -- Goodrich explained that, "In this year of the program, because of where we set performance threshold, you actually don't have to report on a full year of quality in order to be successful, and be above that threshold."
However while the law allows "hardship exceptions" for the Advancing Care Information category, those exceptions do not extend to the quality category.
Those who plan to use their EHR and run into a problem should contact the agency, she said.
"We are definitely open to thinking about how we can address those circumstances within the bounds of what the statute allows us to do," Goodrich added.
Finally, Goodrich reminded the audience that the data submission period for 2017 ends on March 31, 2018 and that data can be entered here.
Participants will not find out whether they receive an upward, downward, or neutral adjustment until everyone's data has been submitted, she noted.