Remember the last time you went to the beach or the lake? Did you run and throw yourself into the water, or did you slowly wade in? Perhaps you are of the first type, and after hearing that 2017 is the year to start preparing for MACRA (Medicare Access and CHIP Reauthorization Act of 2015), you dove right in, figured out whether you were MIPS eligible and started your practice toward the best possible financial position. If not, this post is for you.
First step, if you haven’t already, go and read our post If You’ve Never Heard of MACRA, Your Practice Could Be in For Some Big Losses. In that post you will learn that under Medicare’s new MACRA program, to avoid penalties (and maybe even earn bonuses) for your practice in 2019 you will need to submit patient care data from 2017, either through a Merit-based Incentive Payment System (MIPS) or an Alternative Payment Model (APM).
Speaking to an audience of fellow neurologists at the 2017 annual meeting of the American Academy of Neurology (AAN), Gregory J. Esper, MD, MBA said “Ninety-nine percent of you will be eligible under MIPS.” If you are not sure if that includes you and your practice, here are the eligibility requirements for MIPS, as provided by the AAN:
You are a Part B clinician who bills greater than $30,000 a year.
You take care of more than 100 Medicare patients a year.
You are a physician, PA, NP, or Clinical Nurse Specialist or certified registered nurse anesthetist.
You choose to report as an individual or a group.
You can also check if you need to submit data to MIPS by entering your NPI number on this Centers for Medicare and Medicaid Services (CMS) webpage. If you are eligible for MIPS but are worried that we are already more than half way through the data collection year (2017) there is good news: Under the MIPS program, you can avoid penalties by submitting even a minimal amount of data. CMS offers three levels of participation in MIPS:
- TEST: Avoid a penalty by submitting some 2017 data
- PARTIAL: Get a small positive payment adjustment by submitting data from a 90-day period during 2017
- FULL: Submit data from all of 2017 to maximize positive payment adjustment
Eric M. Cheng, MD, MS, a neurologist and health services researcher who joined Esper at the annual AAN meeting to speak about MIPS, acknowledged the difficulty in preparing for MACRA and the MIPS option. In consolation he emphasized that “MIPS is an extension of existing CMS programs such as Physician Quality Reporting System (PQRS), Meaningful Use, and Value-Based Payment Modifier.” For this reason, don’t forget about the strategies you have already found to optimize performance in those programs, because they can apply to MIPS. Additionally he offered a few of his own suggestions:
1. Make sure that you are categorized as a neurologist or neurology subspecialist according to CMS
Confirm that your specialty is listed in Medicare’s Provider Enrollment Chain and Ownership System (PECOS), so you aren’t mistakenly listed as a patient’s primary care provider.
2. Code comprehensively to capture severity of disease
Not every patient with a neurological diagnosis needs the same amount of care. For example, with a patient with Parkinson’s, make sure you code for co-morbidities or complications like depression, pressure ulcers, or pneumonia that you are also managing, so the patient’s level of care is fully accounted for.
3. Don’t forget to code for chronic conditions that you are managing
“Each diagnosis has to be assigned each calendar year if the condition is being ‘monitored, evaluated, assessed, or treated,’” says Cheng. “Chronic diseases such as coronary artery diseases, diabetes, and chronic obstructive pulmonary disease are not curable; therefore, they should be reassigned annually.”
If you are still overwhelmed by MACRA and MIPS, there are many more educational resources on the AAN’s MACRA page or the CMS’s MACRA page. Also, CMS has resources available to help small or rural practices navigate their way through MIPS. Look for your State and available resources on this free download. Just remember you are not alone, a quick look and you will find a hand to help lead you through these waters.