On Tuesday, June 20, the Centers for Medicare and Medicaid Services (CMS) issued its proposed rule
for Year 2 of the Quality Payment Program (QPP), established under MACRA. Several of AANEM’s suggestions were adopted in the proposed rule. Of key importance is that CMS is, essentially, providing for another transition year. Under this rule, it is estimated that 94% or more of eligible clinicians would earn a positive or neutral payment adjustment. For information about the rule in effect for the current year, visit AANEM’s MACRA webpage: https://www.aanem.org/Practice/Medicare/MACRA
Based on a cursory review of the rule, it appears that CMS listened to extensive feedback provided by various medical associations and groups, including the AANEM, and made several changes to the QPP based on physician input. Some of the biggest changes involve additional accommodations for small practices (defined as practices with 15 or fewer eligible clinicians):
Increases the low volume threshold exemption to $90,000 or less in Medicare Part B allowed charges OR 200 or fewer Medicare Part B patients (previously was $30,000 or 100 patients);
5 points automatically added to the final MIPS score for small practices;
A hardship exemption for small practices for the Advancing Care Information (the EHR requirement – formerly Meaningful Use) category; and
Creates “virtual groups” to allow solo or small practices to participate in MIPS together.
There are also several changes to the requirements of each of the four categories of MIPS (Quality, Advancing Care Information, Improvement Activities, and Cost) which should help ease the burden on eligible clinicians. For example, clinicians will be allowed to continue to use 2014 edition certified EHRs (CEHRT) and the Cost category will continue to count for zero percent of the final MIPS score in 2018.
The proposed rule allows for a 60 day comment period during which time AANEM will be enlisting the help of AANEM member volunteers and working with key stakeholders to draft a comprehensive response. CMS will publish the final rule in the fall of 2017. The policy staff at AANEM is diligently reviewing all 1,058 pages of the proposed rule to determine how the changes will affect AANEM members. AANEM will continue to keep its members informed of key provisions and welcomes any and all input from AANEM members. Please contact firstname.lastname@example.org
with any questions or concerns.
For detailed information about the current and proposed MACRA rules, attend the MACRA
course at the AANEM Annual Meeting in Phoenix, AZ on Friday, September 15 from 1:30-5:30pm. Register for the meeting here: https://www.aanem.org/Meetings/Annual-Meeting/Register