Page 9 - March 2017

MACRA and MIPS:

Have You Started Collecting

Performance Data Yet?

BY KEVIN N. FINE, MHA

We are well into 2017, which means if you haven’t
already figured out a plan for collecting and reporting
performance data under the Medicare Access and CHIP
Reauthorization Act of 2015 (MACRA), you are running
out of time.
Fortunately, this year is a transition year with reduced
reporting requirements for physicians and healthcare
organizations participating in the Merit-Based Incentive
Payment System (MIPS). However, those who fail to
report a minimum amount of performance data this year
will feel the pain in 2019 when they receive a 4% nega-
tive payment adjustment on reimbursements – and that BY KEVIN N. FINE, MHA
penalty amount is set to increase in future years.
2017 MACRA Reporting Options
To avoid negative Medicare payment adjustments under MIPS, you need to choose
one of the following reporting options for 2017:
• Full-year reporting: If you submit a full year of 2017 data, you may be eligible for
a positive payment adjustment, depending on your performance results.
• Partial-year reporting: If you submit performance data for a minimum of a con-
tinuous 90-day period in 2017, you may have a neutral adjustment or earn a positive
payment adjustment, depending on how much data you submit and your results.
• Minimum reporting: If you report a minimum amount of data for 2017 (e.g., one
quality measure, one activity in the improvement activities category), you can avoid
a negative payment adjustment.
In addition, you need to decide if you will be reporting as an individual or as a
group. For more information, visit the Quality Payment Program website.
Timeline
Under the MACRA final rule issued in October 2016, providers can start collecting
performance data as early as January 1, 2017. Need more time? You have until the
start of the fourth quarter of 2017 (October 2nd) to begin collecting data. However,
keep in mind that the less data you report, the lower your chances of qualifying for
a positive adjustment.
March 31, 2018, is the deadline to submit 2017 performance data to the Centers
for Medicare and Medicaid Services (CMS), regardless of which reporting option you
choose.
CMS is making it relatively easy for healthcare providers to meet the initial report-
ing requirements and avoid a negative payment adjustment in 2019 – as long as you
don’t wait too long to act. Remember, accuracy in your performance data is para-
mount, so if you don’t already have a proactive documentation management process
in place, you may need to establish one now.
Consider engaging a qualified healthcare consultant who can help you weigh the
pros and cons of the 2017 reporting options and develop a MACRA reporting plan
that works best for your organization.
Kevin Fine is a director of healthcare advisory services in the Miami office
of Kaufman Rossin, one of the Top 50 CPA and advisory firms in the U.S.
He can be reached at kfine@kaufmanrossin.com.

Thank you to the sponsors

of our Winter Networking

Chocolate and Wine Tasting:

• All Star Recruiting

• Aurora Diagnostics

• Danto Builders
• Saltz Michelson

• Workforce Insight

South Florida Hospital News southfloridahospitalnews.com March 2017 9