Beginning in 2019, those who participate in Merit-Based Incentive Payment System (MIPS) will have their base payments calculated using the Medicare Physician Fee Schedule but those payments will be adjusted – either up or down – based upon the clinicians MIPS score. Those who participate in Alternative Payment Models (APMs) will receive automatic 5% payment updates for five years. Some providers with low Medicare participation can be exempted from either MIPS or APMs.
It is important to note the definition of “participate” for purposes of these updates. During the first few years of the program, providers will only need to receive a certain percentage of their revenue from a qualified APMs as opposed to 100% of their revenue from a qualified APM. Though this percentage increases each year, physician practices will be able to balance their revenue stream across multiple payment systems and could still qualify for APMs while also receiving revenue through other payment systems. This poses challenges for the practice in terms of keeping track of not just how much money is coming in, but where is it coming from? What percent of monthly revenue came from APM? What percent of total revenue for the year has come from an APM?
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is only ten months old and there is still much work to be done as it jumps from paper to practice. Throughout this year, stakeholders will continue to offer their ideas and the Administration will begin to publish regulations on the official criteria for both MIPS and APMs. The frame is almost built. Construction on the rest of the house is about to begin.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Kirk Reinitz, CPA