Physician Practice

CMS releases small practice MACRA factsheet

Physician Practice Insider, May 31, 2016

Although physician practices may welcome some of the changes MACRA and MIPS will bring, other changes raised concerns that some physicians will be put at a disadvantage. CMS’ regulatory impact analysis indicated that the quality and resource use components of MIPS would have a negative impact on many small, solo, and rural physician practices. In response to concerns raised by physicians, CMS released a MACRA and MIPS fact sheet for small practices.

The fact sheet, released May 13, clarifies that CMS based the regulatory impact analysis on 2014 data. At that time, most small and solo physician practices did not report performance data, CMS says, leaving a data gap that skewed the calculations. In addition, the projections CMS included in the proposed rule were not calculated with the special accommodations the agency created to allow greater flexibility for small practices. These accommodations are designed to alleviate the projected negative impact.

The fact sheet highlights some of the accommodations in MIPS and advanced alternative payment models (advanced APM) for physicians in small, solo, or rural practices. Certain measures in MIPS will be inherently difficult for these physician practices to excel in, CMS acknowledges, and the agency built a degree of flexibility into the measures to offset these issues.
Physicians or physician groups who treat a low volume of Medicare patients, less than or equal to $10,000 in Medicare charges and less than or equal to 100 Medicare patients, are excluded from MIPS payment adjustments.

Small and solo physician practices will also be able to take advantage of group reporting under MIPS by joining virtual groups. Although the virtual group program has not been finalized, CMS is seeking feedback on how virtual groups should be constructed and plans to make the technology easy for physicians to use. Virtual groups should be available by the second year of MIPS.

CMS will allow physicians to adjust their MIPS score based on the availability of applicable measures in a performance category. If there are not enough measures that apply to a physician in a category, CMS would not include that category in his or her MIPS score. The weights of other MIPS categories would be adjusted to make up the difference.

MIPS includes adjustments to reduce the burden of reporting measures, according to the fact sheet. Providers will be able to report quality, advancing care information, and clinical practice improvement activities through a single reporting mechanism, and they can earn bonus points through additional reporting or participation in an APM.

MIPS performance categories will also offer flexibility and exceptions specifically for small, solo, and rural practices.

Small and rural practices can also take advantage of incentives by participating in an advanced APM. CMS is proposing unique advanced APM financial risk standards for certain medical home models such as the comprehensive primary care plus model (CPC+). The fact sheet notes that the majority of practices in the comprehensive primary care model, the precursor to CPC+, are small or rural practices.

CMS invites physicians in small, solo, or rural practices to submit comments. Comments will be accepted until June 27.

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