MACRA and MIPS: Have You Started Collecting Performance Data Yet?

Kaufman Rossin | South Florida Hospital News & Healthcare Report | March 2, 2017

We are well into 2017, which means if you haven’t already figured out a plan for collecting and reporting performance data under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), you are running out of time.

Fortunately, this year is a transition year with reduced reporting requirements for physicians and healthcare organizations participating in the Merit-Based Incentive Payment System (MIPS). However, those who fail to report a minimum amount of performance data this year will feel the pain in 2019 when they receive a 4% negative payment adjustment on reimbursements – and that penalty amount is set to increase in future years.

2017 MACRA Reporting Options

To avoid negative Medicare payment adjustments under MIPS, you need to choose one of the following reporting options for 2017:

  • Full-year reporting: If you submit a full year of 2017 data, you may be eligible for a positive payment adjustment, depending on your performance results.
  • Partial-year reporting: If you submit performance data for a minimum of a continuous 90-day period in 2017, you may have a neutral adjustment or earn a positive payment adjustment, depending on how much data you submit and your results.
  • Minimum reporting: If you report a minimum amount of data for 2017 (e.g., one quality measure, one activity in the improvement activities category), you can avoid a negative payment adjustment.

In addition, you need to decide if you will be reporting as an individual or as a group. For more information, visit the Quality Payment Program website.

Timeline

Under the MACRA final rule issued in October 2016, providers can start collecting performance data as early as January 1, 2017. Need more time? You have until the start of the fourth quarter of 2017 (October 2nd) to begin collecting data. However, keep in mind that the less data you report, the lower your chances of qualifying for a positive adjustment.

March 31, 2018, is the deadline to submit 2017 performance data to the Centers for Medicare and Medicaid Services (CMS), regardless of which reporting option you choose.

CMS is making it relatively easy for healthcare providers to meet the initial reporting requirements and avoid a negative payment adjustment in 2019 – as long as you don’t wait too long to act. Remember, accuracy in your performance data is paramount, so if you don’t already have a proactive documentation management process in place, you may need to establish one now.

Consider engaging a qualified healthcare consultant who can help you weigh the pros and cons of the 2017 reporting options and develop a MACRA reporting plan that works best for your organization.