The Medicare Accessibility and CHIP Reauthorization Act (MACRA) introduced several changes to the physician reimbursement framework. MACRA replaced the Sustainable Growth Rate formula with the Quality Payment Program (QPP) to provide incentives that emphasize value and quality of care over volume. The QPP incorporates three existing quality reporting programs (PQRS, Value-Based Payment Modifier and Medicare EHR Incentive Program/Meaningful Use) and adds a fourth category, Improvement Activities, into one program.
Under the QPP, clinicians can participate in either the Merit-based Incentive Payment System (MIPS) or in Advanced Alternative Payment Models (APMs) to avoid downward payment adjustments and potentially receive upward adjustments. CMS estimates for the first few performance years a majority of clinicians will follow the MIPS track.
ACR Bulletin: A Perfect Fit
Radiologists need only the facts and minimal effort for successful year-two QPP participation.Watch: MACRA – CMS Quality Payment Program Year 3: An Overview for Radiologists
Quality Payment Program Year 2
Under the QPP, clinicians can participate in either the Merit-based Incentive Payment System (MIPS) or in Advanced Alternative Payment Models (APMs) in order to avoid downward payment adjustments and potentially receive upward adjustments. Payment adjustment for 2020 payment year (based on 2018 reporting) ranges from -5% to +5%. CMS has approved the ACR National Radiology Data Registry (NRDR) as a Qualified Clinical Data Registry (QCDR) for 2018. Radiology group practices can continue to use the ACR NRDR QCDR to satisfy 2018 MIPS requirements.
CMS anticipates a majority of clinicians will participate in the MIPS track. MIPS allows Medicare clinicians to be paid for providing high-quality, efficient care through success in four performance categories as shown below. Each category is weighted and added into a final MIPS performance score:
- Quality (50%): To complete this requirement, radiologists will need to report up to 6 quality measures, including an outcome measure, with 12 months of data. Quality improvement will be calculated based on performance, with up to 10 percentage points available. If there is not sufficient data to calculate quality improvement, 0 percentage points will be given. View the 2018 MIPS Quality Measures.
- Promoting Interoperability (25%): Most ACR members will be reweighted to zero in this category as non-patient-facing clinicians or hospital based eligible clinicians, but data may be submitted if clinicians would like to receive credit.
- Improvement Activities (15%): Radiologists will be required to attest completion to up to 4 improvement activities. Small, rural and shortage area practices or non-patient-facing MIPS physicians need two improvement activities to meet full performance score. Activities must include at least one high-weighted activity. View the 2018 MIPS Improvement Activities.
- Cost (10%): The cost category will measure Medicare Spending per Beneficiary (MSPB) and total per capita cost (similar to the previously known Value-Based Modifier Program). Cost will be calculated using claims and will not require data submission.
Highlights of QPP Year 2:
- Minimum of 12 months performance period for the Quality category
- The performance threshold has been raised from 3 points to 15 points
- A MIPS score of 15 avoids negative adjustment; a score of 70+ earns the exceptional performance bonus.
- Use of appropriate use criteria (AUC) for diagnostic imaging will qualify as a high-weighted improvement activity if physicians attest the use of AUC through a qualified clinical decision support mechanism for all advanced diagnostic imaging services ordered
- Small and rural practices are exempt from the QPP if they bill for less than or equal to $90,000 to Medicare or treat less than or equal to 200 patients per year
- Non patient facing clinicians and small practices (defined as 15 or fewer providers) are exempt from meeting advancing clinical information submission requirements and the percentage is reweighted to quality.
- Small and rural practices will receive 3 points for all reported measures regardless of data completion, as well as 5 bonus points as long as data is submitted on at least one performance category
For more details please view the ACR summary of the QPP Final Rule impact on Radiology and the CMS Quality Payment Year 2 Fact Sheet.
Quality Measures Most Relevant to Radiology
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