Health Center Regulatory Issues, Health Center State Policy

Update on MACRA Implementation

By now many of you have heard of the new Medicare Quality Payment Program (QPP), born out of the Medicare and CHIP Reauthorization Act of 2015 (MACRA) that went into effect this year.   The QPP completely revamps the way Medicare pays its providers and is made up of two tracks, the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (AAPM).

Also by now, you have hopefully seen NACHC’s fact sheet on the QPP and have heard that MIPS will not impact the way that Medicare pays Federally Qualified Health Centers (FQHCs), as they have their own unique payment methodology in Medicare are not paid on the Medicare Physician Fee Schedule.  However, if a health center bills the Medicare Physician Fee Schedule (Medicare Part B) for services outside the FQHC service package, those providers may be impacted by MIPS.  There is a low volume threshold that exempts providers that see fewer than 100 Medicare beneficiaries or bill equal to or less than $30,000 in Medicare charges annually or are newly enrolled Medicare clinicians.  Please note, the low volume threshold is calculated either by group or individual, depending on how the center decides to bill Medicare Part B.

CMS has just launched an online “Lookup Tool” for providers to enter in their 10 digit National Provider Identifier (NPI) to determine if he or she is eligible for the Merit-Based Incentive Payment System (MIPS), or exempt and if so, the reason for the exemption. On top of this, CMS is also sending out letters to providers to let them know if they are exempt from MIPS.  Please keep an eye out for these important letters or use the “Lookup Tool” to fully understand how your providers may be impacted by the QPP.

If you have questions on this or any other Medicare related issue, please contact Susan Sumrell.