MACRA Exemption floor increases, but other small practice accommodations get mixed reviews.

The final rule for MACRA’s second year of 2018 will decrease the number of physicians required to participate. This coming year providers with less than $90,000 in Medicare Part B charges or fewer than 200 Medicare patients are exempt from both penalty and potential bonus. CMS expects there to be 934,000 exempt providers in 2018.

Exemptions are somewhat a double edged sword for those that have already expended the effort to meet MACRA-MIPS requirements. Investments in EHR (Advancing Care category), Practice Improvement category activities as well as the effort expended to create data capture points for quality measures (QPP) could now go unrewarded if a provider falls under the volume threshold.

In late fall CMS Administrator Seema Verma announced a “Patients over Paperwork” initiative in a meeting with key healthcare stakeholders. She discussed a new approach termed “Meaningful Measures” that seeks to change focus from evaluating processes to assessing, she said “those core issues that are the most vital to providing high-quality care and improving patient outcomes.” She highlighted providers’ frustration with reporting metrics into the electronic health records (EHR), asserting that currently, “the burden associated with reporting quality measures outweighs their utility.” She announced that CMS will travel the country to gain insight on what aspects of regulatory compliance should be changed to allow providers to spend more time with patients. (1)

However not all announced changes appear to be consistent with Verma’s stated goals. “MGMA is very disappointed that CMS quadrupled the length of the quality reporting period under MIPS from the current 90 days to 365 days in 2018,” Anders Gilberg, SVP of Government Affairs at MGMA stated. “This fourfold increase to the quality reporting requirements is in stark contrast the agency’s statements that the final rule reduces regulatory burdens. CMS is in effect prioritizing quantity over quality and giving physicians less than 60 days to prepare for the 2018 MIPS requirements.”(2)

Among the most important changes from 2017 to 2018 is the beginning of the “Utilization” measurement as part of the MIPS calculation. In 2018 10% of a MACRA-MIPS score is calculated automatically by CMS from claims data by comparing a patient’s HCC score to the provider’s Medicare cost for that patient. This calculation eventually becomes 30% of a provider’s MACRA-MIPS score.

A new “virtual group” MIPS reporting option was part of the final rule for 2018, but little time – only until 12/31/17 – was given for organizations to band together to potentially improve their collective MACRA-MIPS score. Expect to hear more in 2018 about this new MACRA element.

(1)   Shannon Firth, Washington Correspondent, MedPage Today October 26, 2017

(2)   Jeff Byers, Healthcare Dive, November 3, 2017