RE: MIPS Participation
From: Michaele A Crawford, DPM
I have been collecting data for participation in the MIPS program for 2018. I have recently found that I have been exempted for reporting for 2018. The majority of my eligible patients have switched to the Medicare advantage plans. I received a small bonus of 1.29% for 2017 reporting. This bonus will amount to an estimate of less than an $800 increase to my bottom line for 2019 since it does not apply to the advantage plans. It would certainly ease the load on my office to not record this data anymore, as well as free up treatment room time.
I am willing to sacrifice $800. My concern is that if I do not report for 2018, and discontinue collecting the data, what is coming down the road in changes to this system? Will I just end up going back to reporting in 2019 or 2020? It would be aggravating to have to reinstate the protocols and retrain staff. Is there anything else I should be taking into consideration? I would appreciate feedback.
Michaele A Crawford, DPM, Butler, PA
From: Michael L. Brody, DPM
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.
Michael L. Brody, DPM, Commack, NY
From Ron Freireich, DPM
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.
Dyane Tower, DPM, MPH, MS, APMA Director, Clinical Affairs, Bethesda, MD
RESPONSES/COMMENTS (MACRA) - PART 1B
From: Joseph Borreggine, DPM
I use this form from Safestep in my practice to assess any patient who is considered a "fall risk" in my practice. .
Joseph Borreggine, DPM, Charelston, IL
RESPONSES/COMMENTS (MACRA) - PART 1A
From: Jeffrey D. Lehrman, DPM
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