|UCAOA Warns Proposed Medicare Payment System Could Result in Less Beneficiary Access|
On June 27, UCAOA submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to its proposed rule implementing a new Medicare payment system under the Physician Fee Schedule.
Once finalized, the new payment system will take effect in 2019, with payment tied to the performance of physicians or other clinicians in 2017.
In its letter, UCAOA emphasized the need for additional accommodations for eligible clinicians in small practices, including urgent care centers, for them to be successful participants in the new Medicare pay-for-performance system — the Merit-Based Incentive Payment System (MIPS). UCAOA cautioned that urgent care centers may limit their Medicare patient mix if meeting the proposed requirements are perceived as too costly, burdensome, or otherwise unattainable.
Under MIPS, eligible clinicians will have their Medicare fee schedule payments adjusted based on their performance in four categories: Quality, Resource Use, Clinical Practice Improvement Activities, and Advancing Care Information (i.e., use of certified electronic health records).
Under the proposed rule, eligible clinicians can get an exemption from MIPS by participating in an Advanced Alternative Payment Model or by meeting CMS’ proposes low-volume threshold which is defined as individual MIPS eligible clinician or group who, during the performance period, have Medicare billing charges less than or equal to $10,000 and provides care for 100 or fewer Part B-enrolled Medicare beneficiaries.
Concerned that few urgent care providers would meet this definition, UCAOA joined with the American Medical Association in asking that CMS instead set the low-volume at $30,000 and to eliminate a minimum patient count.
UCAOA also suggested that, at least initially, eligible clinicians who bill under place of service 20, should be exempt from the program until more appropriate metrics for urgent care providers are established. Alternatively, UCAOA recommended several changes that CMS could make to its proposed regulations that would ease the program burden for urgent care providers, including an exemption from the resource use category and reporting fewer quality measures.
A final rule is expected this Fall, but eligible clinicians should begin to calculate the cost risks and benefits of MIPS participation. For the first year of the program, poor performers, including those who choose not to report any of the required quality metrics, would receive a maximum downward adjustment of 4 percent of Medicare physician fee schedule payments.
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