08/20/2016 Eric Lullove, DPM
MACRA Preparations (Pam Thompson)
With all due respect, I have to disagree with
Ms. Thompson regarding the “9%” reduction in
reimbursement under MACRA is recoupable. When
the policy is fully implemented, as it has
already begun, physicians are already targeted
based on their utilization cost and outcome
generated by the eQCMs and under MIPS.
Beginning THIS year, CMS and HHS have begun
tying and targeting 30% of all reimbursement to
quality initiatives. This includes PQRS. By
2018, the number will be 50%. By 2021, 90%. It
is not a matter of whether as a provider you
WANT to participate by reporting quality
measures, it is a question of whether or not
you want to participate in MEDICARE at all.
For those of us who work in higher than normal
Medicare populations (FL, TX, OH, AZ), this may
not be a question to answer, as we need the
volume Medicare population to help drive our
incomes and practices. For other parts of the
country where Medicare populations are smaller
or more insignificant to a a practice
population, it may benefit to remove oneself as
a Medicare provider. Keep in mind, that CMS is
late to the game and most of the private
insurers, PPO and HMO, have adopted quality-
based payment models YEARS ago.
See posted letter for chart
As you can see here it is not just a 9% hit.
For example, Provider A who continues to have
high cost and low outcomes will have a greater
negative impact — as a result, a colleague in
the same geographic area, Provider B, who
outperforms that provider receives the (+)
payment adjustment with a multiplier incentive,
thus taking the revenues from provider A and
giving it to Provider B. This is the inherent
problem with certain providers treating a
higher risk population than others— there is no
reward for taking care of a brittle diabetic
over one who is stable.
Overall, for CY2017, if there is no delay in
MACRA, a provider who attains a Composite score
of 100 based on these four components:
*Quality (50%)
*Advancing Care Information (ACI, renamed from
Meaningful Use) (25%)
*Clinical Practice Improvement Activities
(CPIA) (15%)
*Resource Use (10%)
Will have an upward incentive payment of 14%
(+4% payment adjustment + 10% incentive bonus).
If a practice is earning $200,000 in Medicare
reimbursements, then the adjustment + bonus =
$28,000. However, the negative will be -
$8,000. For a single service provider, asking
them to figure out how to recoup $36,000 just
to not participate in MACRA compliance is
enough reason TO PARTICIPATE. Just to make
sure everyone understands, if you are
participating at max incentive in 2020, you can
earn up to 37% of your reimbursable income,
which is based on your 2018 reporting data. So
if you keep the same $200,000 in reimbursement
for 2020, then your total incentive bonus is
$74,000. If you still plan on staying out and
have a 9% negative adjustment ($18,000), then
figure out how to recoup around $91,000 in lost
revenue.
Eric J. Lullove, DPM, Boca Raton, FL
