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How CMS Supports Underprivileged and Small Medical Practices?

We cannot disregard the services of small medical practices or rural practices or facilities in underprivileged areas. They, despite their limited resources, strive to provide quality healthcare services to patients. However, it doesn’t mean that they cannot be included in the Quality Payment Program (QPP).

CMS (Centers for Medicare and Medicaid Services) helps such practices to unload their burden and enjoy some of the relaxations. Moreover, they assist small medical practices via technical assistance that is customized and free.

Whom do we call a Small Medical Practice?

A small medical practice refers to a facility with fifteen or fewer clinicians. However, practices working in rural areas, or designated health professional shortage areas (HPSAs) or designated medically undeserved areas (MUAs) are more prone to find privileges.

Given below is the support program for small, undeserved, and rural practices that comprises of both program-level and practice-level assistance for MIPS 2020.

Program-Level Support for Small Medical Practices

  • CMS helps with data submission
  • CMS assists in determining if you’re included in the program
  • CMS supports in understanding the general requirements of QPP
  • CMS offers advice on identifying and choosing appropriate MIPS measures and activities
  • CMS guides on transitioning into an Alternative Payment Model (APM) or Advanced APM

Practice-Level Support for Small Medical Practices

  • CMS helps in assessing practice readiness for QPP
  • CMS encourages participating in a quality improvement initiative
  • CMS helps developing strategies for implementing Certified Electronic Health Record Technology (CEHRT)
  • CMS offers support in forming partnerships with peers, local stakeholders, regional partners, and more

Medical practices can find external help for QPP MIPS 2020 participation on their official website. Moreover, CMS has taken charge for quite some time, especially in the pandemic, to support clinicians with their quality data submission meaningfully. It also helps physicians to enjoy incentives and benefits in the payment year 2022.

An Overview of MIPS 2020 Participation Flexibility

CMS continues to exclude individual MIPS eligible clinicians or groups with less than or equal to $90,000 in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS) or less than or equal to 200 Medicare Part B patients, who are furnished covered professional services under the Medicare PFS or less than or equal to 200 covered professional services under the Medicare PFS.

Virtual Group Participation

Individual healthcare professionals or medical practices with a staff of ten or fewer clinicians can participate as a “virtual group” in MIPS 2020 with other medical practices.

Clinicians can also report data for rendered quality services via Medicare Claim Submission type for Quality performance category as individuals or as a group.

Reporting Flexibility in Quality Category

If small practices report quality measures even if they don’t comply with the data completeness requirement, CMS rewards them with three points in MIPS 2020.

Moreover, small or under-served practices will also receive six bonus points for their quality reporting even if it is just one measure.

Reporting Flexibility in Promoting Interoperability (PI) Category

QPP MIPS 2020 Promoting Interoperability participation accounts for the 2015 Edition Certified Electronic Health Record Technology (CEHRT) use.

If any medical practice qualifies for the following cases, it is exempt to report PI category and can request to reweigh its points to zero.

  • A small medical facility
  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability to CEHRT
  • Decertified EHR technology

In such cases, medical practices are asked to fill out the Hardship Exception Application by the end of this year.

Reporting Flexibility in Improvement Activities (IA) Category

The reporting requirements for the Improvement Activities are the same as the year before. There are no added or topped up criteria. However, for healthcare facilities operating in rural areas or health professional shortage areas that are unable to meet the criteria, are exempted from strict policies.

For them:

  • Medium-weighted activities hold 20 points of the total Improvement Activity performance category score
  • High-weighted activities hold 40 points of the total Improvement Activity performance category score

What are the Reporting Rules for Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and Critical Access Hospitals (CAHs)?

There is no change of policies for Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and Critical Access Hospitals (CAHs).  The details are as follows.

Any medical practice being part of an RHC or FQHC is exempted from MIPS 2020 participation.

If any medical practice bills for Medicare Part B services exclusively through the RHC or FQHC payment methods,  it does not qualify for payment adjustments under MIPS because it doesn’t cater to these facilities.

If you are a part of an RHC or FQHC and bill for Medicare Part B services under the Physician Fee Schedule (PFS), then payment adjustment for rendered services would be subjected to the MIPS payment adjustments. It also accounts without the exception of exclusive cases or when the billing is below than the low volume threshold.

A medical practice under Critical Access Hospital (CAHs) can participate in MIPS 2020, but the following payment adjustment implications will be applied. Moreover, if a practice operates in a Method I CAH, the payment adjustment would apply to services they bill under the Physician Fee Schedule (PFS), but not to the facility payment.

The practitioners under Method II CAH can receive payment adjustments the same as in the year 2019 if they have not assigned billing rights to the CAH. In an otherwise case (if you practice in a Method II CAH and assign billing rights to the CAH), the payment adjustment would apply to the Method II CAH payments.

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