CMS just released its proposed MACRA rule for 2018 and we are pleased to report that it contains major changes that, if finalized, will substantially reduce the burden on allergists. (Note: the requirements for 2017 are unchanged. Check our MIPS toolkit for 2017 reporting options for allergists.)
The burden of MIPS reporting was one of the topics we discussed in a meeting with high level staff of Tom Price, Secretary of Health and Human Services, during the Strike Force meeting in May (pictured here). We are gratified the concerns that many of us voiced have been heard and action has been taken.
The biggest change for 2018 is the low-volume exclusion. Under the new proposal, physicians with less than $90,000 in Medicare allowed charges per year or fewer than 200 Medicare patients per year would be excluded from the Merit-based Incentive Payment System (MIPS). The current rule sets the threshold at $30,000 or 100 patients. The Advocacy Council and the College had taken an aggressive position on this and submitted comments that CMS raise the limit to $100,000. We are very gratified that CMS has given us almost what we asked for. We believe this is a substantial victory for our specialty and especially for allergists in small practices. If the proposal is adopted only 42% of allergists/immunologists will be subject to MIPS compared to almost 63% under the previous rules.
In another major shift, CMS is now proposing that physicians in small practices of 15 or fewer could receive a hardship exemption from the advancing care information requirements (i.e., EHR reporting) of MIPS if they can demonstrate significant barriers to compliance.
Other proposed MIPS changes of importance to our specialty,several of which were proposed by the Advocacy Council, are:
- Reporting: Increasing ease of reporting by allowing physicians to report using multiple methods (e.g., claims, registry, EHR).
- Cost Measure: Postponing until 2020 the implementation of the MIPS cost measure
- Bonus for Improvement: Creating bonus points for practices that improve their quality and cost scores from one year to the next
- EHR Flexibility: Allowing physicians to use either the 2014 or 2015 Edition of Certified EHR (CEHRT)
- Bonus for Complex Patients: Giving bonus points for physicians that treat complex patients
- Bonus for small practices: Giving bonus points to physicians in small practices that submit data on at least 1 performance category
- Virtual Groups: Implementation of Virtual Groups option
The proposal also makes it easier for alternative payment models (APMs) to qualify by changing risk requirements for certain APMs.
We are continuing to review and analyze the proposed rule and will provide more detail in the future.