08/19/2016 Pam Thompson
MACRA Preparations (Neil H Hecht, DPM)
I believe Dr. Hecht is correct. There's really
nothing to "prepare" for at this point. Anyone
already playing the MU/PQRS game now should be
fine, as MIPS will be a bit more streamlined,
if you believe the pundits. Since nothing has
been released yet, how would preparation begin?
Maybe we all just start to bite our nails and
pace around the office at lunch every day til
someone notices little beads of sweat on our
brow.
If "preparation" means buying an EHR for the
first time, or god-forbid, buying another one
because the one you have is evil and stupid,
DON'T. Want an EHR for Meaningless Use? Get the
free one and be done. It won't be any worse
than 95% of the ones out there.
If a practice hasn't started playing the
Meaningless Use/PQRS game yet, they may not
have to for another year or so. And depending
on the practice owner's preferences, he may not
have to worry about it, ever.
2016 will very likely become a 90-day reporting
period for Meaningless Use instead of the full
year. PQRS, of course, remains a year long
exercise in useless tracking, but your EHR
should make it fairly simple to comply.
MIPS is increasingly likely to be put off
another year to 2018, which means there may be
one more year of a 90-day reporting period
(2017) for MU/PQRS. Then when MIPS is triggered
in 2018, it will be a 90-day reporting period
as well, because they'll need lots of physician
buy-in.
So complying, if you want to, won't be as bad
as it will be in the future.
Dr. Hecht mentions that CMS says 87% of
practices will face a negative adjustment, and
asks why even try to avoid it?
Physicians ask me the same thing regularly.
Should they try to comply? My answer: it
depends.
If you like regulations for regulations sake
(some actually do), then the answer is yes,
comply until your head explodes.
For everyone else, I say, "Do what works for
you now; don't worry about the penalties,
because it's EASY to offset them with less
effort than it probably will take to comply".
(The caveat, of course, is that at some point,
attempted non-compliance may be futile in the
Borg-value future, but I think that is some
years away.)
Think about it. A 50% Medicare, median sized
podiatry practice has gross revenue of about
$350,000. These practices are likely to have
more Medicare patients than larger practices,
who often have a younger population driving
higher revenue. So it's this sized practice
(and smaller) that would have the most to lose
as a percentage of revenue.
CMS states that Medicare breaks down to about
70% straight Medicare, and 30% Medicare
Advantage. Since Medicare Advantage doesn't
count in the reward /penalty game, affected
gross revenue would be the practice's revenue
for straight Medicare only.
As an example, beginning (2%) penalties for a
$350K practice with 50% Medicare, and 70% of
that Medicare qualifying (straight Medicare B)
here's the math:
($350K X 50%) X 70% = $122,500 x 2% = $2450.
At 9% penalty, the ultimate penalty ding would
be $11,025. Over the next few years, could
someone generating $350,000 a year figure out a
way to increase gross revenue by $11,000? You
betcha.
The penalty for larger practices is not likely
to be proportional as a percentage of gross
revenue. Most large practices are not huge
Medicare practices, so by percentage and dollar
cost, their penalty for non-compliance may be
significantly less.
With a little cost waste work, any practice
could actually increase profitability by much
more than the penalties being exacted, without
more patient visits.
I submit that the effort to comply with
MU/PQRS/MIPS currently creates far more adverse
effects in compliance (stress, cognitive
exhaustion, labor cost-waste, etc.) than in
non-compliance.
The financial penalty may be well worth the
gain enjoyed by decreased stress, freedom from
regulatory oppression and reduced cognitive
overload.
I've been completing detailed profit/cost
analyses of podiatry practices for over 2 years
now, and have found more than 23% of gross
revenue is cost-wasted on average, meaning that
the money is spent, but doesn't "buy" anything.
More than half this waste can be recovered and
drop to the bottom line as practice owner
income, without too much effort.
That means to me that many, many podiatrists
can completely ignore MU and PQRS and have a
profitable, productive practice. They have to
manage a bit (no business does well with an
absence of management) but with some basic
focused actions, they'll more than make up the
loss due to MU/PQRS/MIPS penalties, if they
don't want to play the compliance game.
I've often recommended that my clients ignore
MU and PQRS, as their cost-waste analysis
showed it cost more to comply than they would
lose in penalties. A no-brainer.
If, at some time in the future, compliance is
better for a practice than non-compliance, then
figuring out cost effective ways to do that
ensures no financial loss.
Meanwhile, freedom from being conscripted to
play a game you want no part of is a benefit to
enjoy right now.
Pam Thompson, Thompson & Associates, Guerrilla
Podiatry
