Changes CMS Final Rule Release Will Introduce in 2017 and Beyond

CMS (Centers for Medicare & Medicaid Services) on Friday, October 14, 2016, announced the much awaited Medicare Access and CHIP Reauthorization Act (MACRA) final ruling. This new rule finalizes the new payment system and healthcare quality reforms for all those physicians who seek reimbursements for Medicare services. In this way, the practitioners will see an increase or drop in their reimbursement based on how well they are doing under the revised metrics of quality and costs. The 2,398-page Final Rule manual includes transition information that will prove useful in the year 2017. Over time, this policy will go on a multi-year journey that will particularly focus on letting clinicians transition according to their comfort, getting feedback appropriately and providing meaningful support to improve the program over time.

Following are the biggest changes that have come into effect with the release of the Final Rule:

  • Higher Low-Volume Threshold: Only those who bill $30,000 or more in Medicare Part B or attend over 100 Medicare patients in a year need to bill under MIPS. This condition is going to require about two-thirds of Medicare Part B providers to file their report accordingly.
  • Cost Measures Moved: The earlier version had cost measures as a vital portion of the final MIPS score. The new version will still permit reporting of cost metrics, however they will not be counted during the first year of reporting. Its actual value will now be available under ‘Quality’ segment of the composite score.
  • CPIA (Clinical Practice Improvement Activities) requirements lowered: It is mandatory to report 4 out of 93 activities for at least 90 days for not getting penalized. However this condition does not apply to institutions registered as medical homes.
  • Advanced APMs scope expanded: Since the addition of more organizations into advanced APMs, CMS believes that as many as 70,000 to 120,000 (about 5%-8%) providers who bill Medicare Part B will actually be eligible to benefit from Advanced APM in 2017. This is vital since this will make them eligible to get 5% incentive of all Medicare payments.
  • ACI (Advanced Care Information) recording minimum cut conditions: ACI is what measures how the electronic health records (EHRs) must be used. The Final Rule reduced the count for reporting criteria from 11 to 5 from 2017. However, it is still essential to report everything for at least 90 days to get maximum benefits under this category.
  • Modified first year reporting volume: There are now new guidelines which define what one needs to report for complying with the new requirements. The penalty or the benefit for reporting data in different formats will be as follows:
  • Non-reporting: Those who qualify and participate in MACRA but don’t report will have to incur 4% negative adjustment on final Medicare reimbursement.
  • Submitting Sample Data: Qualifying for reimbursement by submitting only a small portion of what is required will be enough to avoid a penalty, but won’t be enough to secure any incentive. Any more reporting made later in the year will lead to a small increase in the disbursed payment.
  • Exceptional Performance Adjustment: Those who report Quality Payment Program (QPP) data for the entire year in one go, they will be rewarded with a moderate pay hike. If their final score exceeds 70, they will also become eligible to receive an additional incentive under exceptional performance adjustment scheme.

To learn more, join expert speaker Kim Garner-Huey, MJ, CHC, CPC, CCS-P, PCS, CPCO, in an audio conference, titled ‘CMS MACRA Final Rule and its Impact on your Coding and Billing’ on Wednesday, February 15, 2017. This session will provide an update on CMS MACRA Final Rule Guidelines and Determining Changes in Documentation, Coding & Billing.

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