The concept of value-based reimbursement under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) that came into force on January 1, 2017 ties physician reimbursement to quality of care rather than the volume of services. While experts say that the long-term impact of this policy on medical practices, hospitals, medical billing companies is uncertain, it is expected that the focus on quality will improve efficiency and patient outcomes while reducing costs.
Providers have two options to participate in MACRA – Advanced Alternative Payment Models or the Merit-Based Incentive Payment System (MIPS). As the law penalizes poor quality and high cost, they will need to adhere to various regulations to avoid punitive action. Most anesthesia providers will be required to participate in MACRA. A recent article in Anesthesiology News discussed the implications of new system for participating anesthesiologists, how they benefit from being “non-patient-facing”, and how they can avoid penalties.
Enjoy the Benefits of Being “Non-Patient-Facing”
Under MACRA, facility-based clinicians such as anesthesiologists are described “non-patient-facing”. MACRA grants certain benefits and exemptions to non-patient-facing clinicians on the basis that facility-based clinicians do not have significant control over the electronic health record and as they need to coordinate with other stakeholders to engage in practice improvement activities. As a result, non-patient-facing clinicians:
- Are excluded from the advancing care information category
- Have a lower reporting requirement for practice improvement activities – they need report on only one high-weighted or two medium-weighted practice improvement activities compared to patient-facing clinicians who have to report on two high-weighted activities or four medium-weighted activities
Provider status – whether non-patient-facing or not – is determined based on the list of patient-facing CPT codes published by CMS. Providers who bill 100 or fewer patient-facing CPT codes are in the non-patient-facing category and those who bills more than 100 codes are considered as patient-facing.
However, anesthesia CPT codes do not feature on the list of non-patient-facing CPT codes. But the list includes evaluation and management (E & M) services, many pain procedures, and codes for intubation, endotracheal, emergency procedure, as well as insertion of a central venous catheter, age 5 years or older. Therefore, to determine their status, the Anesthesiology News article recommends that anesthesiologists ask their medical billing company to compare CPT codes on the list of patient-facing encounters with historical billing data for their practice.
Exemption from the Advancing Care Information Category
As non-patient-facing clinicians do not have to report the advancing care information category, most anesthesia providers are exempt from this requirement. Hospital-based clinicians and CRNAs are also excluded from this category. Anesthesiologists can apply for a yearly hardship exemption on the grounds that they lack control of the electronic health record.
Reporting as a group can also eliminate the requirement of pain physicians to report the advancing care information category. If 75% of your group is non-patient-facing, then the entire group is considered non-patient-facing.
Follow Quality Measure Submission Rules to Avoid Penalties
By following CMS rules for submitting quality measures in 2017, clinicians can avoid a negative payment adjustment in 2019. They can avoid assessment of a penalty under the Quality Payment Program (QPP) by submitting one quality measure or one performance improvement activity, or the four to five required advancing care information measures.
Anesthesia providers will participate in MACRA via the MIPS option. As most are exempted from the advancing care information category, it is likely that they will report only quality measures and practice improvement activities in 2017. The cost category will not be considered this year and 85% of their MIPS score will be determined by quality reporting and 15% by practice improvement activities. Under the QPP, the minimum requirement to avoid a negative payment adjustment is 1 measure, 1 time, for 1 patient.