The proposed rule
is just 3 weeks old, and analysts are still trying to determine exactly how the new payment system will affect physicians, but one section in the 962-page MACRA proposal set off alarm bells across the healthcare field: the projected impact on small practices.
In the proposal, the Centers for Medicaid and Social Services (CMS) projected that in 2019, the first year that payment adjustments will go into effect under MACRA, 87 percent of solo practices and 70 percent of practices with two to nine eligible clinicians will see a negative Medicare payment adjustment. The total impact is estimated to be $300 million on solo practitioners, and $279 million for practices of two to nine clinicians.
These numbers understandably alarmed physicians and physician groups. However, CMS was quick to respond with the publication of a fact sheet
for small and solo practices, which pointed out that the regulatory impact analysis contained in the proposed rule was, “…based on 2014 data when many small and solo practice physicians did not report their performance [under Medicare’s current quality programs].” CMS goes on to describe the accommodations for small and solo practices contained in the proposed rule that are designed to create more flexibility for these practices, as compared to the current Medicare quality programs. Some of the main proposed accommodations include:
Low Volume Exclusions: Eligible clinicians who have less than or equal to 100 Medicare patients and who have no more than $10,000 in Medicare charges would be excluded from the MIPS payment adjustment
Flexibility in MIPS Measures: If there are not sufficient applicable measures and/or activities in one of the four MIPS performance categories for an eligible clinician, that category would be excluded from the MIPS score and the remaining categories would be re-weighted to make up the difference.
Group Reporting: Under MIPS, eligible clinicians would have the option to be scored as a group across all of the performance categories. The proposal also discusses the development of “virtual groups” that clinicians would be able to join starting in 2018, but the information on this option is still quite vague.
The fact sheet explains additional proposed accommodations under MIPS, as well as how the Advanced Alternative Payment Models pathway may work for these practices. Additionally, the sheet notes that there will be funding available for technical assistance for small practices during the first five years of the MACRA implementation. For more information and materials related to the proposed rule, visit CMS’s Quality Payment Program