On October 14, 2016 the Centers for Medicare and Medicaid Services (CMS) released the final rule implementing payment changes under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA replaced the Sustainable Growth Rate formula with new payment models designed to move away from fee-for-service and reward value rather than volume.
A key component of MACRA is a new payment model known as the Merit-Based Incentive Payment System (MIPS) which emphasizes quality. The final rule also addresses Advanced Alternative Payment Models (APMs) where group practices can receive higher payments in return for taking on a greater degree of risk. This Alert focuses on MIPS, the payment model expected to have the greatest impact on psychologists in Medicare.
Providers who are subject to MIPS are not mandated to report under the new payment models but will face significantly higher reductions in their Medicare payments each year that they do not participate. Psychologists will not be subject to MIPS until 2019.
Psychologists and MIPS
While psychologists are excluded from MIPS in 2017 and 2018, the final rule shows how CMS will apply the current MIPS requirements to other healthcare providers. Providers reporting under MIPS are known as MIPS eligible clinicians (MIPS ECs) and in 2017 this will include physicians and extenders such as physician assistants and certain advanced practice nurses.
CMS is offering providers who are not yet MIPS ECs, such as psychologists and clinical social workers, the opportunity to practice reporting under MIPS. This would be done by reporting MIPS measures, as discussed further below, and submitting the data to CMS. The psychologist could then receive feedback on whether their reporting was successful. Psychologists who practice reporting in 2017 will not be subject to MIPS penalties nor will they be eligible for MIPS incentives.
While psychologists are not required to report in 2017, APAPO’s registry, APAPO PQRSPRO, is still available to collect, review, and submit MIPS data. Any psychologist or other behavioral health provider interested in practicing MIPS reporting before 2019 is welcome to use the APAPO registry at the current annual cost of $199.
Low Volume Threshold Exemption
CMS has taken several steps to reduce the burden of MIPS reporting following the receipt of thousands of comments on the agency’s proposed rule on MACRA. The topic of greatest interest to commenters, including the American Psychological Association Practice Organization (APAPO) in its June 24, 2016 comment letter, was the low volume threshold designed to exempt small providers from MIPS reporting. CMS originally proposed a low volume threshold for providers treating 100 or fewer Medicare beneficiaries and having equal or less than $10,000 in Medicare allowed charges. As requested by APAPO, CMS agreed to bifurcate the two threshold components. In 2017 providers will be exempt from MIPS reporting under the low volume threshold if they treat 100 or fewer Medicare beneficiaries or they have $30,000 or less in Medicare charges.
The new standards for the low volume threshold apply only to MIPS reporting in 2017, which does not apply to psychologists but the threshold may change by the time psychologists are included in MIPS in 2019. CMS states in the rule that it anticipates the low volume threshold will evolve over time.
Transition to MIPS Reporting
To assist in the implementation of the new payment system, CMS has made 2017 the “transition year” and will allow MIPS ECs to choose how they wish to report. MIPS ECs can report for as little as a 90-day period or up to the entire calendar year. For 2017 the reporting options are:
Do not report under MIPS and have Medicare payments reduced by 4%
Submit one quality measure, one improvement or some Advancing Care Information measures to avoid a loss in payment
Submit 90 days of reporting data and possibly receive a small increase in payment
Report for the full year and possibly receive a moderate increase in payment
All adjustments for 2017 MIPS reporting will be applied to payments in 2019. Some MIPS ECs will receive higher payments depending upon the quality results of their data.
MIPS data comes from the four categories:
Quality (replaces PQRS) – Report 6 quality measures including an outcome measure.
Improvement Activities (new category) – Report up to 4 improvement activities.
Advancing Care Information (replaces Meaningful Use) – Submit up to 9 measures.
Cost (replaces the Value-Based Modifier) – No reporting required as CMS calculates the data from claims. CMS has announced this category will not be counted as part of the MIPS composite score in the 2017 transition year.
Category 3, Advancing Care Information, is a major concern for psychologists as they were not included in the Behavioral Health Information Technology incentives offered to other healthcare providers in past years. APAPO brought this to the attention of CMS in its June 24th comment letter and advised the agency to take this into consideration when psychologists enter the MIPS program in 2019. CMS states in the final rule that it recognizes not all MIPS ECs have experience with Meaningful Use and that ECs who do not have any applicable measures in this category in 2017 need not submit Advancing Care Information.
The Medicare payment changes announced in the MACRA final rule are the first for a new program that CMS expects to evolve over the coming years. To assist providers with the transition CMS created a Quality Payment Program website: https://qpp.cms.gov/education
APPAO will provide psychologists with additional information about the details in the final MACRA rule as part of its ongoing effort to prepare psychologists for the changes ahead. In addition, the final rule on the 2017 Medicare fee schedule is expected to be released in early November as discussed in our August 22 and August 31 Action Alerts. Psychologists with questions are welcome to contact Government Relations at 202-336-5889 or by email at firstname.lastname@example.org.
For more information, contact APA Practice Organization Government Relations Office at Pracgovt@apa.org or (202) 336-5889. Visit APA Practice Organization on-line at APAPracticeCentral.org/Advocac y.