The Centers for Medicare and Medicaid Services (CMS) announced that they have adjusted certain aspects of the Quality Payment Program (QPP) in response the Public Health Emergency (PHE) caused by the COVID-19 coronavirus outbreak. CMS has extended the deadline for reporting 2019 Merit-based Incentive Payment System (MIPS) data and has relaxed the criteria for avoiding a penalty in 2021 based on submission of 2019 data.
Participation in the Quality Payment Program (QPP) means that you always have several years’ information in play at one time. The score you earned from submitting 2018 data will now be impacting your Medicare reimbursement in 2020; you have just completed your 2019 performance and it’s time to submit your data; and finally, you now have to begin your 2020 performance year.
The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website. The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results. According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold.
Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient. The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring. This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.
Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along. One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams. This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021. This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.
The year 2019 marks the third reporting period under the Medicare Incentive-based Payment System (MIPS). Radiology groups’ performance this year will determine their positive or negative Medicare fee schedule adjustment for payments in 2021, just as this year’s Medicare payment adjustment was determined by performance in 2017.
With the 2017 MIPS reporting year behind us, we now know that practices that achieved the highest possible Final Score of 100 points will receive 2.02% more Medicare reimbursement than the basic fee schedule for 2019. This increase is compared with the possibility of a 4% payment reduction for practices that did nothing, and a zero-percent adjustment for practices that did the minimum amount of reporting. In between the minimum level and a perfect score, the fee schedule positive adjustment varies on a sliding scale computed by Medicare.
In our recent article we explored the ways radiology groups can begin to move toward participation in Alternative Payment Models (APM*) as an option in place of working within MIPS under the Medicare QPP. But what does APM participation mean for a radiology practice, and what should radiologists look for to begin moving in this direction?
When Congress finalized the fiscal 2017 federal budget on February 9, 2018, the bill1 contained some changes that will affect the Medicare Quality Payment Program (QPP) in the coming years. Nothing in the bill changes Medicare payment levels or the MIPS2 reporting requirements for 2018. There is, however, a change that affects the 2018 performance year low-volume exclusion.
Here is a summary of the changes:
The Centers for Medicare and Medicaid Services (CMS) threw a surprise into the Quality Payment Program (QPP) Final Rule for 2018 when it included the Cost Category as 10% of the MIPS Final Score for 2018 reporting. The QPP Proposed Rule issued a few months earlier stated that Cost would be zero-weighted for 2018 as it had been in 2017. So what does this mean for radiology?