RE: 2018 MIPS Rule Could be Murphy's Law for Many Podiatrists
From: Lawrence M. Rubin, DPM
On November 2, the Centers for Medicare & Medicaid Services (CMS) released its final rule governing its Medicare Quality Payment Program in 2018. Among other changes, the CMS has changed the low-volume threshold that excludes participation in the Merit-based Incentive Payment System (MIPS) to $90,000 or less in Medicare Part B allowed charges, or 200 or fewer Part B beneficiaries. The current threshold is $30,000 or less in allowed charges, or 100 or fewer beneficiaries.
I am sure many podiatrists affected by this rule will not cry over not having to comply with MIPS requirements to avoid Medicare payment cuts. But on the other side of the coin, how will this affect the many podiatrists thinking they are doing the right thing for their practices by already participating in the 2017 MIPS performance period based on the current low-volume threshold? It looks like raising the low-volume threshold in 2018 would prohibit those below the threshold from opting into and having their payments adjusted under MIPS. This begs the question of the status of those already participating. Are practices that are above the threshold in 2017 -- but below the new 2018 threshold -- now not qualified to participate in MIPS in order to receive future payment increases?
Readers have brought up the question what will happen when providers with a smaller Medicare population are exempt from potential MIPS Penalties. Many practices that could receive a penalty will not because they are below the low volume threshold. Many practices that could receive an incentive will not because they also are below the low volume threshold.
The threshold for getting a penalty is moving from 3 to 15, making it easier to be penalized and more difficult to get a bonus. With all of the changes that will impact the amount of incentive monies that high performing practices can earn, it is difficult to predict the impact on the amount of incentive received.
One thing that is clear, with smaller practices not being eligible for MIPS, these practices will NOT be able to collect exceptional provider bonuses, so there will be more available from that pool for the larger practices that are exceptional providers.
I’m wondering if there is another hidden issue here, so correct me if I’m wrong. Bonus money for participating in MIPS is coming from penalties assessed to physicians who do not participate (so I'm told). So, isn’t raising the threshold to $90,000 or less in Medicare Part B allowed charges, or 200 or fewer Part B beneficiaries, going to, in effect, decrease the potential “pool” of bonus money available from non-participating physicians’ penalties since fewer physicians will be eligible to participate in MIPS? Sounds like physicians participating in MIPS in 2018 will be working harder for less bonus money. Sound familiar?
Ron Freireich, DPM, Cleveland, OH
RE: Clarification About the APMA Registry
From: Dyane Tower, DPM, MPH, MS
All APMA members can use the APMA Registry to complete MIPS attestations for this year—and avoid a penalty in 2019—regardless of their EHR vendor.
MIPS participation includes three components: Clinical Practice Improvement Activities (CPIA), Advancing Care Information (ACI), and Quality Performance Category (QPC). The APMA Registry allows users to submit their CPIA and ACI attestations for 2017 even if their EHR is not integrated with the system. Users with an integrated EHR can also submit their quality measures for the QPC.
There is only one source for MACRA information and that is qpp.cms.gov. This is the CMS website for MIPS. On this website, you will find that there is a Clinical Practice Improvement Activity called, “Implementation of Fall Screening and Assessment Programs”. There are also three Quality measures dealing with falls. I think the one you are asking about is the Quality measure #154, “Falls: Risk Assessment". On the QPP website, you can read every detail about this measure, the denominator and numerator, as well as the codes for reporting.
Jeffrey D. Lehrman, DPM, Springfield, PA
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