Kentucky REC presented a MACRA Overview webinar to help organization’s understand how this will impact the way they deliver care.
To listen to the webinar, please click here.
The following questions were asked on the webinar. We have answered the Frequently Asked Questions below.
Please note: If you asked a question and do not see an answer here, please contact us directly and we will be more than happy to speak with you.
1. Are anesthesiologist excluded from MIPS?
Anesthesiologist may be exempt from participating in the MIPS program or certain categories of the program dependent on the place of service codes billed. Once CMS has the NPI lookup feature available you will be able to use this tool to find out for sure. However, until that time, it would be important to evaluate the percentage of “patient facing” encounters the provider has during 2016 to determine eligibility outside of the standard low volume threshold.
2. If we have a high percentage of Medicaid patients, do we need to worry about MACRA?
MACRA exclusions are based on volume, not percent of revenue, so we would suggest you check the dollar amount. An Eligible Clinician (EC) is excluded if he/she bills less than $30,000 or sees less than 100 Medicare patients.
3. How are providers identified as working in an FQHC so they won’t get a penalty for not reporting?
CMS will look at three snapshots of time from 2016 to determine eligibility. If the provider meets the low volume threshold of less than $30,000 Medicare Part B and/or less than 100 Medicare patients then they would be excluded. Traditionally, FQHC providers would not bill Part B outside of ancillary services. However, it is critical that you verify each provider to ensure avoidance of penalty.
4. We are an RHC, are we excluded from participating in MACRA/MIPS?
While RHC payments billed under the all-inclusive payment methodology are excluded, any Medicare Part B payments are included. This would typically include anything billed under ancillary testing (Lab, Radiology, etc). We would encourage you to look at your Medicare Part B billings and determine if your providers have billed less than $30,000 or seen less than 100 patients to be excluded. This would be per provider, if reporting on an individual provider level, or at the group level, if group reporting.
5. We are in an ACO (that is not considered an advanced Alternative Payment Model). Do we still have to participate in MACRA?
Yes, ACO participants are required to report under MACRA. There is not a separate reporting option for the Quality Performance category, as that is reported through your ACO. You would still report on the ACI and IA categories.
6. We are part of an ACO and attesting to PCMH this year, are we under MIPS or APM?
Unless your ACO is considered an advanced Alternative Payment Model, ACO participants are MIPS eligible.
7. We treat nursing home residents and patient engagement is our biggest challenge. The 5% for ACI will be tough. Any advice?
One suggestion is to partner with those nursing homes and see if they will assist in talking about the benefits of the patient portal. Use fliers/brochures to help keep the message in front of patients and families. Have your care team members, most importantly the physicians, talk about the portal. Studies have shown that patients are more responsive if their physician asks them to use the portal versus other staff members.
8. Any guidance on successful strategies to improve patient utilization of portals? Can you provide more information on the “opt-out” option? Is this a viable solution to meeting this requirement?
One of the best strategies to improve use of patient portals is to have the physician engage the patient in discussing portal benefits. Many physicians are encouraging patients to use the portal to request/cancel appointments, request prescriptions on medications when refills expire, and to send private messages to care team members. All these options depend upon the functionality of your particular portal vendor. One caveat to the “opt out” option-you must have a way to show a list of patients who “opt-out” and most systems do not yet have this ability automated. Therefore, you would need a manual process to provide documentation if ever audited.
9. Are psychologists considered Eligible Clinicians?
Under MIPS, psychologists are not considered Eligible Clinicians (ECs) in performance years 2017 and 2018. They should plan on reporting in 2019 (for payment year 2021). While it is not required, it might be beneficial to begin reporting prior to 2019 as a way for the provider to receive feedback and begin implementing strategies that would strengthen their score by 2019.
10. We cannot report using the public health reporting (KHIE) due to the costs constraints. How can you help?
For Advancing Care Information, there is no longer an “all or nothing” approach. Therefore, not having connectivity to KHIE or a public health organization will not prevent you from successful participation.
11. Is full year reporting required to be eligible for part of the $500 million pool for scoring greater than 70 points?
No, a full year is not required. However, a full year reporting period could increase your chance to achieve a score of greater than 70. It is important that you evaluate your reports prior to submission to determine the best submission methods and performance periods.
12. Is the low volume threshold only for one year?
The low volume threshold is based on a “look back” of your previous year’s activity.
13. Is the low volume threshold per provider or per organization?
It depends on how you plan to report. If you do individual reporting, then it is per provider. However, if you plan to do group reporting, then it would be collective for your group.
14. Does MACRA only apply if we are applying for the Medicare EHR Incentive Program? If we are applying for the Medicaid EHR Incentive Program can we also participate in the Medicare EHR Incentive Program?
MACRA is the legislation that created the Quality Payment Program which encompasses the PQRS program, the Medicare EHR Incentive Program and the Value Modifier. If a provider is an Eligible Clinician then the provider would need to participate in one of the two tracks: MIPS or Advanced APM. In addition, if the provider participates in the Medicaid EHR Incentive Program, then the provider can continue to participate in that program through 2021. However, this would require the provider to attest to both one track of the QPP program as well as the Medicaid EHR Incentive Program to avoid penalty and potentially qualify for the Medicaid EHR Incentive program monies.
15. I currently participate in the Medicaid EHR Incentive Program. Do I also have to participate in MACRA?
Medicaid EHR Incentive Program will continue through 2021. If you would like to continue to participate in the Medicaid EHR Incentive Program, you can do so, but it will require dual attestation (MU requirements for Medicaid Program and ACI requirements for QPP Program).
16. Is ACI reporting at the organization level?
ACI reporting can be done at the TIN level or individual NPI level. Depending on the size of your practice and the vendor you use for data capturing, you may have a group level report that can be pulled to determine the group’s performance.
17. How will we attest for MACRA?
Currently there are several different methods to use to submit data for the MIPS program. Check out the QPP.CMS.GOV website to learn more.
Register today to learn about your required Security Risk Analysis. Stay compliant!
Please join us for a discussion on HIPAA Security Rule basics and best practices. We will cover tips, tools, and tactics for implementing thorough compliance in 2017.
The Kentucky REC Privacy and Security experts will be hosting a webinar to share the requirements and processes for completing an annual Security Risk Analysis. Our expert panel will discuss the required/addressable standards of the HIPAA Security Rule and defensible steps that practices can take to ensure they are meeting all compliance requirements. In this conversation our experts will ensure that organizations are equipped with compliance best practices and the most up-to-date methods for completing a Security Risk Analysis. In addition, our experts will cover the Office of Civil Rights (OCR) audit protocols, highlighting how the Office of Inspector General (OIG) concentrates their efforts across the Privacy, Security, and Breach Notification Rule. We will discuss the Kentucky REC Security Risk Analysis and Project Management Services that help practices mitigate gaps.
- Covered Entities who electronically transmit any health information
- Business Associates
- Compliance Officers
- Information Technology Managers
- Understand the frequency and method for conducting a Security Risk Analysis
- Learn the National Institute of Standards and Technology (NIST) and Office of Civil Rights (OCR) recommended steps to conduct a Security Risk Analysis
- Learn best practices and tactics to reduce breaches in your organization
- Understand OCR audit protocol and how to prepare if you are a Covered Entity or Business Associate
- Discuss the services Kentucky REC experts provide in order to help medical practices with compliance
We look forward to our discussion. HIPAA Security Rule Webinar: April 11th at 12:00 pm EST
The Patient-Centered Specialty Practice is a National Committee for Quality Assurance (NCQA) recognition program that extends the Patient-Centered Medical Home (PCMH) concepts to specialists. Specialty practices committed to access, communication and care coordination can earn accolades as the “neighbors” that surround and inform the medical home and colleagues in primary care.
This cohort framework is designed to accelerate your journey to NCQA PCSP Recognition within a 14-16 month period. Through our expert training, coaching, and resources, your staff will be well-prepared to carry out the practice transformation process.
Now is the perfect time! By receiving recognition as a PCSP, your organization will receive full points in the Improvement Activities category of the Merit-Based Incentive Payment System under the Medicare Access and CHIP Reauthorization Act (MACRA).
To learn about the PCSP program and our Cohort services, join us for a FREE educational webinar on April 4th, 2017 at 12pm.
Don’t miss the opportunity to be a part of something special as we work to transform healthcare in Kentucky!
For more information about joining the Kentucky REC PCSP Cohort, please email Megan Housley or Stephen Williams or call 859-323-3090.
Is your clinic interested in learning Continuous Quality Improvement (CQI) methods which could lead to better rates of Lung Cancer Screening and tobacco cessation in your patient population…FOR FREE?
The Kentucky Ambulatory Network is looking for Primary Care Clinics to participate in a potential National Institute for Health funded project to assess whether Continuous Quality Improvement implementation can increase rates of lung cancer screening and tobacco cessation referrals in a primary care patient population. All materials, training, and a practice facilitator are free to clinics, and clinics receive financial reimbursement for participation.
Please download the flyer: Lung Cancer Screening CQI project, and contact the Kentucky Ambulatory Network at KAN@uky.edu or (859) 323-6713.
Eligible professionals, eligible hospitals, and critical access hospitals (CAHs) participating in the Medicare Electronic Health Record (EHR) Incentive Program must attest using the Medicare & Medicaid EHR Incentive Program Registration and Attestation System by Monday, March 13, 2017 at 11:59 p.m. ET.
Important Notice Regarding eReporting CQMs:
If you are an Eligible Professional (EP) with an attestation status of “Pending eReporting,” you have selected to report your Clinical Quality Measures (CQMs) electronically through one of the mechanisms below. If you have not submitted your CQMs electronically through one of the available mechanisms for Physician Quality Reporting System (PQRS) by the deadline, your attestation will expire and you will not meet meaningful use. You may choose to MODIFY your attestation and enter your CQMs manually to attest successfully to meaningful use. NOTE: The deadline for electronic reporting for EPs is 3/31/2017 at 8:00 p.m. ET.
If you are an Eligible Hospital or CAH with an attestation status of “Pending eReporting,” you have selected to report your 4 Clinical Quality Measures (CQMs) electronically through the QualityNet Secure Portal for both the Hospital Inpatient Quality Reporting (IQR) and Medicare EHR Incentive Programs. If you do not submit your CQMs electronically through the QualityNet Secure Portal by the submission deadline, your attestation will expire and you will not meet meaningful use. You may choose to MODIFY your attestation and enter your 16 CQMs manually to attest successfully to meaningful use. NOTE: The deadline for electronic reporting of CQMs for Hospitals is 3/13/2017 at 11:59 p.m. PT.
To enter your 16 CQMs manually:
- Click MODIFY in the Attestation tab
- De-select eReporting and choose Option 2: “I will manually enter my CQMs into the online attestation.”
- Enter your CQMs and submit your attestation. You will receive a “Successful attestation” confirmation page.
Deadline to Modify is Monday, March 13 at 11:59 p.m. ET.
Providers who submitted their CQMs electronically will see “Pending eReporting” until after the submission period closes and the outcomes are scheduled to be transmitted. For hospitals, this will occur around late March or early April 2017; for EPs, it will happen around late April or early May 2017.
The prior eCQM status of “Pending eReporting” will be replaced by one of two messages: “Locked for Payment” or “Expired.” If the message reads “Locked for Payment,” the Medicare EHR Incentive Program is indicating the provider completed the electronic reporting option for CQMs successfully. If the message reads “Expired,” the message is indicating the provider did not complete the CQM electronic reporting option successfully.
For more information, visit the Registration and Attestation page on the CMS EHR Incentive Programs website.
Contact the Kentucky REC at 859-323-3090