Heads up to family physicians in small practices -- CMS says it's prepared to make your path to success in new Medicare payment models smoother.
As most physicians recall, on April 27, HHS released a long-awaited proposed rule intended to implement key provisions of the Medicare Access and CHIP Reauthorization Act (MACRA). That rule was subsequently published in the May 9 Federal Register.(www.federalregister.gov)
For several weeks now, the AAFP has been working through the massive regulation with a keen eye toward identifying provisions that could adversely impact family physicians and their patients.
CMS is also on alert and is scrambling to make sure physicians understand and are prepared for the big changes coming in how they are paid by Medicare. As part of that effort, the agency recently released a resource aimed specifically at physicians in small practices across the country, many of whom have expressed significant concerns about the proposed regulation's disproportionate burden on them.
The fact sheet, titled "Flexibilities and Support for Small Practices,"(www.cms.gov) notes that "CMS is sensitive to the unique challenges that small practices face in different types of communities, and the Quality Payment Program,(go.cms.gov) as proposed, would provide accommodations for various practice sizes and configurations."
CMS concedes that a regulatory impact analysis suggested that the rule "would negatively impact small practices."
That's of great significance to the AAFP because the latest available member census indicated that slightly more than 80 percent of the Academy's family physicians work in practices of 15 or fewer physicians; furthermore, some 17 percent of members have primary addresses located in rural areas.
"This paper details the flexibility and support available to small practices and practices in rural or health professional shortage areas," says CMS. Regarding the Merit-based Incentive Payment System (MIPS) -- one of two payment paths physicians may pursue -- CMS outlines specific proposed flexibilities designed "to account for diversity among practices."
For instance, CMS highlights proposals that are small practice-friendly, such as
- low-volume exclusions from the MIPS payment adjustment for clinicians or groups who have $10,000 or less in Medicare charges and 100 or fewer Medicare patients;
- flexibility in MIPS scoring if there are not sufficient measures and activities applicable and available in a MIPS performance category;
- group reporting that allows solo and small practices to join "virtual groups" and combine their MIPS reporting;
- administrative burden reduction in that CMS would remove unneeded measures and reduce administrative burden but still provide meaningful rewards for high-quality health care; and
- simplified reporting made possible through a single reporting mechanism.
The agency notes that the legislation provides $100 million in funding to help small practices with technical assistance and another $685 million to support the Transforming Clinical Practice Initiative.
Lastly, the Health Care Payment Learning and Action Network(hcp-lan.org) -- a public-private partnership designed to align efforts to move toward new payment systems -- provides a place where small practices can discuss ideas and share best practices on how they are moving toward alternative payment models.
CMS invites all stakeholders to submit comments(www.regulations.gov) by the June 27 deadline.
In the meantime, family physicians in practices of all sizes and settings can rest assured that the AAFP fully intends to demand improvements in the proposed rule to ensure that physicians will have every opportunity to succeed.
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