By C. Matthew Hawkins, MD
SIR Economics Committee Member
Many practice leaders across the country waited with anticipation as CMS deliberated and crafted the final rule for the Quality Payment Program (QPP), a key component of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. CMS issued its final rule on Oct. 14, which modified the originally proposed language and impacted how physicians will participate in the Merit-based Incentive Payment System (MIPS) and advanced Alternative Payment Models (APMs). There are a variety of provisions in the rule that affect the interventional radiology community and SIR is working to keep its members up-to-date on these changes.
A change of pace
CMS has acknowledged that nationwide, complete participation in QPP beginning Jan. 1, 2017 may be unreasonable. In response, they have proposed a number of “pick your pace” options that groups follow to avoid negative penalties in 2019 based on 2017 reporting.
- Test the QPP: Submitting partial data in 2017 will avoid negative payments in 2019. CMS has given clinicians a choice to report just one measure from quality, improvement performance, or advancing care information categories to avoid negative payments. But beware, those clinicians that do not participate at all will receive a 4 percent negative adjustment in 2019 payments.
- Participate for part of the calendar year: QPP data can be submitted for any continuous 90-day period in 2017 and potentially qualify for a positive adjustment.
- Participate for the full calendar year: Practices can begin reporting QPP data on Jan. 1, 2017 (as originally intended) and may quality for a positive payment adjustment.
- Participate in an advanced Alternative Payment Model
These modifications allow IR practices some increased flexibility to effectively begin participating in QPP.
Of course, as has been emphasized by SIR for years, we (IR) are a patient-facing specialty. However, the definition of patient-facing versus non-patient facing physicians, as defined by CMS in this rule, has substantial data reporting, and ultimately reimbursement, implications.
- Any physician that reports 100 or fewer patient-facing encounters, will be considered a non-patient-facing, MIPS-eligible clinician.
- Any group with 75 percent or more of their physicians reporting as non-patient facing, can report as non-patient facing clinicians under the group’s TIN.
- The specific codes that define “patient-facing encounters” are yet to be defined. It is unclear whether procedures alone will qualify, or if these encounters will be limited to evaluation and management services.
- Non-patient-facing clinicians are only required to report one high-weighted improvement activity and two medium-weighted improvement activities as part of MIPS. Comparatively, patient-facing clinicians must report two high-weighted and four medium-weighted improvement activities. These improvement activities account for 15 percent of the weighted MIPS payment adjustments in 2019.
Overall, the language in the final rule was responsive to much of the feedback provided by our specialty societies. Groups will be faced with the challenge of determining whether or not interventional radiologists will report as patient-facing or non-patient-facing physicians, which will impact the number of measures that must be reported to CMS. The yet-to-be-determined “patient-facing encounters” will heavily influence whether or not a patient-facing determination is possible for many IRs.
As additional provisions are clarified within and throughout the MACRA legislation, SIR will continue to keep its members up to date so that IR practice leaders can make informed decisions about the future of their groups.