If yours is one of the small clinical practices with less than $30,000 in Medicare revenue or fewer than 100 unique Medicare patients per year, October 2, 2017 will be just another Monday. However, for most Medicare-participating health care practitioners, Monday, October 2, 2017 marks the deadline for significant reporting requirements under the Centers for Medicare & Medicaid Services (“CMS”) Quality Payment Program of the Medicare Access and CHIP Reauthorization Act of 2015 or “MACRA”.

The MACRA, which is a value-based payment regime for Medicare-participating physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists, offers clinicians the following two reporting tracks.

  • Alternative Payment Model or the “APM” track, in which clinicians will directly bear upside and downside risk.
  • Merit-Based Incentive Payment System or “MIPS” track. Under the MIPS track, clinicians are scored by CMS on activity reporting measures related to Quality, Improvement Activities, Advancing Care Information, and Cost.

Importantly, MACRA-covered clinicians who do not elect a track by October 2, 2017 will be assigned to the MIPS track, and will receive a 4% reduction in Medicare payments for fiscal year 2018. Those who choose the MIPS track but do not properly perform and report will also receive up to a 4% payment reduction. Each year thereafter, the activity and reporting requirements increase, along with the negative adjustments for non-compliance. In fact, by 2022, non-compliance will bring a full 9% payment reduction.

The important deadline of October 2, 2017 to choose a track that is right for your practice and business is imminent. If your organization fits the criteria for reporting under MACRA and has questions concerning either programs’ requirements and compliance issues or is seeking further guidance and business or legal strategies, please contact PLDO Managing Principal Gary R. Pannone and business and health care lawyer Joel K. Goloskie at 401-824-5100 or email [email protected] and [email protected].

To learn more about the program, you can also review the American Medical Association’s “10 key steps” action plan at Medicare Quality Payment Program or access Preparing for MACRA infographics published by Advancing the Business of Healthcare. We welcome your comments, questions and suggestions.