The Centers for Medicare and Medicaid Services releases final rule on the Medicare Access and Chip Reauthorization Act of 2015

The rule addresses the Practice Organization’s concerns on advanced care info and the low-volume threshold.

On Oct. 14, a year and a half after President Barack Obama signed the Medicare Access and Chip Reauthorization Act of 2015 (MACRA), the Centers for Medicare and Medicaid Services (CMS) unveiled their final rule for how MACRA will be implemented.

MACRA marks a shift away from a traditional fee-for-service model and toward a quality-based payment framework called the Quality Payment Program. The law:

  • Repeals the Sustainable Growth Rate formula, which was used to calculate payment cuts for providers.
  • Creates a two-track payment system for providers that includes the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model.
  • Consolidates the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the “meaningful use” metric (which measured the use of health information technology) into a single reporting system through MIPS.

Since its release, the Practice Organization’s Government Relations staff has analyzed all 2,398 pages of the rule to understand how MACRA will affect psychologists.

Psychologists and MIPS 

Psychologists will not be eligible to participate in the MIPS reporting system until 2019. Healthcare providers who are eligible to participate — including physicians, physician assistants and certain advanced-practice nurses — are referred to in the final rule as MIPS Eligible Clinicians, or MIPS ECs.

In 2017, CMS is offering MIPS ECs a number of reporting options, including the option to forgo reporting and subsequently have their Medicare payments reduced by four percent in 2019.

While psychologists are not part of that group, CMS is offering them the opportunity to practice reporting under MIPS in 2017. If you choose, you may report your MIPS measures to CMS and receive feedback on whether your reporting was successful. Psychologists who take advantage of this option in 2017 will not be subject to MIPS penalties, nor will they receive MIPS incentives.

The Practice Organization’s registry, APAPO PQRSPRO, will be available to help collect, review, and submit MIPS data for those who are interested in practicing reporting on MIPS measures in 2017.

Providers’ performance data will be measured across four categories:

  • Quality: This measure replaces the PQRS system. Providers will report on six quality measures, including an outcome measure.
  • Improvement activities: Under this new category, providers will report up to four improvement activities.
  • Advancing care information: This replaces the Meaningful Use metric, which is meant to encourage the use of EHRs and other health information technology. Providers will submit up to nine measures.
  • Cost: This replaces the Value-Based Modifier, but won’t be required of providers in 2017.  

The third category, advancing care information, has been a major concern, as psychologists were not included in the Behavioral Health Information Technology incentives offered to other healthcare providers in past years.

The Practice Organization addressed this concern in the June comment letter (PDF, 71KB) submitted to CMS in response to the proposed rule. In the final rule, CMS states that MIPS ECs who do not have applicable measures in this category in 2017 do not need to submit Advancing Care Information.

Low-volume threshold exemption

The June comment letter also asked that CMS reduce the burden of MIPS reporting on small practices. Many groups in the healthcare community made similar requests. In the final rule, CMS responded by making MIPS ECs exempt from reporting under the low-volume threshold if they treat fewer than 100 Medicare beneficiaries or if they have $30,000 or less in Medicare charges.

Psychologists should note that this threshold may change by the time they are included in MIPS in 2019. 

Additional information

2017 is a MACRA transition year, and CMS expects the payment changes announced in the final rule to evolve in the coming years. To assist providers with the transition, CMS has created a Quality Payment Program website.

The Practice Organization will continue to provide psychologists with information about the payment changes under MACRA. In addition, the final rule on the 2017 Medicare fee schedule is expected to be released in early November.

If you have questions about MACRA and how it might affect your practice, please contact the Government Relations staff at (202) 336-5889 or via email.