Now closing out its third year of implementation, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) continues to evolve, and its complexity still poses a challenge to many clinicians. Below, Mollie Gelburd, JD, an associate director of government affairs at Medical Group Management Association, a trade group for practice managers, answers five common questions about the law.
Question 1: Are hardship exemptions available?
Yes, but they are hard to come by, except in extreme cases such as natural disasters. However, exemptions may be easier to obtain for the “promoting interoperability” scoring category. For example, changing EHR systems mid-year or having an EHR become decertified would likely count as hardship exemptions, Gelburd says.
Question 2: How will physicians be scored in 2019?
Beginning this year (which will affect reimbursement in 2021), eight episode-based measures will be added to the cost category, bringing the total to 10 cost measures. Episodic measures are important. “Practices don’t report on costs; the government does it for them. So practices might be assessed on those measures and not know it,” observes Gelburd. All 10 measures fall into one of three categories:
- Annual cost of care
- Acute inpatient medical condition
- Procedural episode
Question 3: How are data reported?
Individuals can report via claims, a qualified clinical data registry (QCDR), or EHRs; group practices have the additional option of a Centers for Medicare & Medicaid Services (CMS) Web Interface or a CMS-approved survey vendor. “QCDR is an attractive option because it allows measures that are outside of MIPS [the Merit-Based Incentive Payment System],” notes Gelburd, granting specialists the potential to develop their own quality measures. However, the downside of QCDR is that it can be expensive.
Question 4: Are EHRs necessary to participate?
No, practices without EHRs can still participate in MACRA; they will simply receive zero points for the promoting interoperability score. If they receive high enough scores in other categories, penalties may still be avoided and bonuses gained.
Question 5: Is it too late to participate in MACRA?
No, practices can still take part, says Gelburd, and the criteria for doing so are relatively lenient. “I would recommend that newcomers look at the list of ‘improvement activities,’” she says. These might include actions the practice is already taking, such as being open for a few hours during weekends. Another activity that could be easy to achieve is “timely communication of test results.” Because the word “timely” isn’t specifically defined, Gelburd suggests that practices could be flexible in interpreting this subcategory.
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