David Levin, MD, professor and chairman emeritus of the radiology department at Jefferson Medical College and Thomas Jefferson University Hospital in Philadelphia, asked a simple question with his Nov. 26 presentation at RSNA 2017: Will the Medicare Access and CHIP Reauthorization Act (MACRA) and the Merit-based Incentive Payment System (MIPS) kill your radiology practice?
Radiologists can breathe a small sign of relief because Levin's answer is no.
“If practices don’t prepare for this stuff, they’re going to suffer some penalties,” Levin told Radiology Business. “I don’t think it’ll kill anybody. Probably every radiology practice in the country is going to have to participate and I think they probably will, but it’ll be a real hassle.”
Levin didn’t think the changes made to MIPS for 2018 made the program any more or less difficult for radiologists. He did point to the introduction of the cost category, which will make up 10 percent of a clinician’s total MIPS score next year, as a challenge for radiologists since they’ll be “responsible for costs” even when they’re non-patient facing.
Among other associations, much of the attention on the final 2018 rule focused on the much higher low-volume exemption thresholds. Clinicians won’t have to participate in MIPS if they bill less than $90,000 in Medicare Part B charges or see fewer than 200 Medicare beneficiaries—up from $30,000 and 100 beneficiaries in 2017. This too, however, was a change Levin didn’t believe would help radiologists stay out of MIPS.
“I would think that most full-time radiologists are going to bill more than $90,000 a year for Medicare patients,” Levin said.
Participation in the Advanced Alternative Payment Models track would also allow radiologists to avoid MIPS participation, but Levin said opportunities in 2018 are “very limited” unless a radiology practice is in the unusual situation of being entirely inside an accountable care organization. More Advanced APM opportunities may open up in 2019 and beyond as specialty societies develop qualifying models.
So with MIPS being unavoidable for most radiologists, Levin offered some tips on how they can increase their chances for success in the new system. One recommendation he made is to use the American College of Radiology’s National Radiology Data Registry (NRDR), which has been approved by CMS as a qualified data registry for MIPS reporting.
Out of the dozens of MIPS measures and NRDR measures available, Levin recommended picking the six which are easiest and most appropriate for their practices. He mentioned fluoroscopy time as a one easy-to-collect measure, as “most fluoro units will have a time stamp.”
An important message Levin hoped radiologists take away from his talk was MIPS and MACRA aren’t going away, despite rumblings by the Medicare Payment Advisory Commission (MedPAC) that the program be scrapped. It may be a hassle, but it’s also a hassle many practices can’t avoid.
“I don’t like this program either one bit, don’t get me wrong," he said. "I’m not a great advocate of MIPS. I think it’s a colossal pain in the butt for everybody, not just radiologists, but all physicians. But I think we have to prepare for the worst and assume this is going to stick around for the foreseeable future.”