MACRA Deadline Oct 2, 2017
The time to fish or cut bait is upon us. Deadline for Data Collection is October 2, 2017, i.e. less than thirty days away. Your answers or lack thereof to the following four questions will help develop your MACRA strategy. N.B. This is only a very preliminary test.
Before answering the four questions below, you will need to:
i) Evaluate your past performance in Physician Quality Reporting System (PQRS), Meaningful Use, and Value-based Modifier. Is it good enough?
ii) Determine your practice resources, strengths, weaknesses, opportunities and threats in order to maximize your performance year and ensure a sustainable advantage over the long run. Do my finances and team support this decision?
iii) Develop, assess, and strengthen your MACRA systems and procedures to ensure minimum performance under the program you choose.
Tempus fugit, so please take action this week. By no means, are these the only evaluations you need to perform, and each of the above-mentioned and four questions below will require more time and resources than you think.Keep in mind these are just a bare minimum as a starting point.
1. Decide which payment track you will participate in 2017, the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (AAPM)? Noncompliance will result in a negative 4% penalty to all Medicare Part B charges in 2019. If you don’t know, do yourself a favor and schedule a practice assessment at your earliest possible convenience.
2. Decide if you want to report your performance data as a group or individual? Hint: choose the one that shows your practice in the best possible light, both options have pros and cons.
3. Decide which pace option is best for your circumstances? Here are your options: Test pace (no real definitive span of time data requirement), Partial Participation - submit data for at least 90 days, Full Participation - submit data for a full year, or Advanced Alternative Payment Model? Keep in mind that eligible clinicians must choose an option in order to avoid a negative four percent (-4%) penalty to Medicare Part B charges in 2019. Please note resent research showed that an additional 5% risk would have added over $800M to participants in the Medicare Shared Savings Program. So, taking the plunge may be your best option, but you need to do your homework.
4. Decide which submission type is best? Qualified Registry, Qualified Clinical Data Registry (QCDR), Claims (individual only), Web Interface (groups of ≥ 25) or Electronic Health Record Direct (EHR Direct)?
Keep in mind your financial risk will increase no matter what you decide, but this author has noticed that historically early adopters will be rewarded or given some consideration to encourage further Part B provider participation. Best of luck on your sojourn. Peace