The report from the Harvey L. Neiman Health Policy Institute describes how, under MACRA, radiologists will be paid through the Merit-Based Incentive Payment System (MIPS). MIPS applies adjustments, both positive and negative, to fee-for-service payments (JACR, December 22, 2016).
In April, CMS published an initial proposed rule for MACRA, renamed the Quality Payment Program (QPP), that will eventually link a large portion of doctors' Medicare payments to the value and quality of care. Actual payment adjustments under MACRA will begin in 2019, reflecting performance during 2017.
Overview and estimation
The first part of the JACR series offers an overview of the proposal for implementing MACRA legislation via the QPP, with particular emphasis on the implications and requirements for radiologists under MIPS.
Because the performance assessment begins in 2017 for payment adjustments in 2019, radiologists must start preparing now, taking actions to ensure future success with the payment program, said Dr. Andrew Rosenkrantz, lead study author, in a statement accompanying the study.
In the second part of the JACR series, researchers found that the special considerations in the new payment models would result in radiologists being evaluated using measures that don't reflect their practices, which are typically characterized by a low level of direct patient interaction that could reduce their reimbursement levels under MACRA.
"MIPS will provide special considerations for physicians with a limited degree of face-to-face patient interaction," said Dr. Bibb Allen Jr., chair of the Neiman Institute advisory board and past chair of the American College of Radiology Board of Chancellors, in a statement. "However, using CMS' proposed criteria for which physicians will receive special considerations, many radiologists will be deemed ineligible for these special considerations and thus be evaluated based on performance categories beyond their control."
Alternative criteria could help ensure that radiologists are given a fair opportunity to succeed in performance reviews under MIPS, study author Rosenkrantz noted.
The study concluded that use of the proposed CMS criteria will result in most physicians receiving special considerations. If billing 25 or fewer evaluation and management services or surgical codes, 72% of diagnostic radiologists would receive special considerations, though such patient encounters will represent only an estimated 2.1% of billed codes among the remaining radiologists who have no special considerations.
Alternative plan for considerations
Were CMS to apply an alternative criterion of billing 100 or fewer evaluation and management codes exclusively, the percentage of diagnostic radiologists receiving special considerations would rise to 98.8%, the study noted. At this level, face-to-face patient encounters would represent about 10% of all billed codes among the remaining radiologists with no special considerations.
The American College of Radiology communicated this information to CMS, advising that determination of special considerations based on direct patient interaction would best be defined by the number of evaluation and management services performed, rather than the number of minor procedures performed. The final CMS rule issued on October 14 reflects the ACR's recommendations, according to the article.
Under the new definition, almost 90% of diagnostic radiologists and almost 40% of interventional radiologists will be eligible for special consideration, and the numbers could rise to 99% and 87%, respectively, if CMS determines that procedural services will not be included in CMS' determination of patient pricing status. The new protections are supported by the data in the second part of the series, the JACR article notes.
The researchers are currently studying the extent of face-to-face encounters between radiologists and their patients, JACR said.
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