Keeping Up With CMS and Changing Healthcare Regulations in 2019 (White Paper)

One of the greatest challenges for physicians and staff in independent practices is keeping up with the changing regulations that dictate so much of the day to day activities in medical practices. Larger clinics and hospital-owned physician groups often have dedicated staff whose sole job it is to stay abreast of current and proposed regulations and payer requirements. Unfortunately, most independent practices don’t have the budget for a Director of Regulatory Affairs. Fortunately, there are some great industry resources available, such as and the various specialty associations websites. And you can download this free resource to stay on top of the changes that will impact your practice in the coming year and beyond.

Free White Paper
Getting Paid in 2019: What Independent Medical Practices Need to Know

While we can’t provide a comprehensive analysis of all of the regulatory changes that will impact the independent practice as well as the rest of the industry in 2019, there are a few key areas that merit a special focus, as they will have the greatest impact from both a regulatory and financial standpoint.

Quality Payment Program Results

CMS recently released some encouraging statistics regarding the participation levels and success rates of the 2017 MIPS program year. Approximately 93% of the eligible clinicians participating in 2017 earned a positive payment adjustment, according to Seema Verma, the CMS Administrator. Another 2% received a neutral adjustment, and 5% received a negative adjustment.

Approx. 93% of participating MIPS clinicians in the 2017 program year earned a positive payment adjustment

As we approach the third year of the QPP MIPS program, there are a few key changes to the program worth noting.

PQRS and Meaningful Use Phased Out

While the positive payment adjustments are somewhat modest, for some practices who previously had received penalties under the Meaningful Use and PQRS programs, the net effect on their revenue will be more signifcant. As the penalties for PQRS and Meaningful Use phased out at the end of 2018, many of those practices who found it too cumbersome to fully participate in those programs will no longer see those dreaded CO-237 adjustments on their Medicare EOBs.

Because of the “pick your pace” approach to MIPS in 2017, many of those practices were able to avoid the penalty and even obtain a slight positive adjustment. While it remains to be seen whether those practices will continue to be successful in avoiding penalties in year two and beyond, the slower pace of implementing MIPS along with the commitment from CMS to reduce the administrative burden on physicians just may be enough to allow more providers to be successful in avoiding negative adjustments. This is all good news for smaller, independent practices.

Increased Point Requirement to Avoid Penalty

CMS increased the minimum number of points required to avoid penalties in 2019. The new threshold to ensure an eligible provider achieves a neutral adjustment will be 30 points, up from 15 in 2018. For those providers who hope to obtain the exceptional performance bonus, they will need a minimum of 75 points, a five point increase from 2018.

MIPS Expands Eligible Clinician Types

An expanded definition of MIPS eligible clinicians now includes the following clinician types:

  • Physical therapists
  • Occupational Therapists
  • Qualifed speech language pathologists
  • Qualified audiologists
  • Clinical psychologists
  • Registered dietitian or nutrition professionals

Physical Therapists and Clinical Psychologists are among the clinician types now eligible for MIPS.

More Help for Small Practices

The final rule for the 2019 QPP contains several items specifically targeted toward helping small practices. Those include:

  • Increased small practice bonus to 6 points and including it as part of the Quality performance category
  • Continuing to award 3 points for submitted quality measures that don’t meet data completeness requirements
  • Offering continued support for small and rural practices through the Small, Underserved, and Rural Support (SURS) technical assistance initiative.

Help for Small, Underserved and Rural Areas

The Small, Underserved, and Rural Support initiative that was funded by MACRA is a ve year program that provides free, customized technical assistance to clinicians in small practices of 15 providers or less. The QPP website provides a link to locate selected providers of these services by state. These organizations provide both program level support and practice level support in the form of helping providers understand the general requirements of the QPP, determining if they are considered a MIPS eligible clinician, choosing appropriate measures and activities for a practice, and assistance with submitting their data. They can also perform practice readiness assessments and assist in developing strategies for implementing Certified Electronic Health Record Technology (CEHRT).

Download the free white paper, Getting Paid in 2019: What Independent Medical Practices Need to Know

2015 Certified EHR Now Required

Beginning in 2019, only EHRs with the 2015 certification will qualify for the QPP. If you have not participated in previous MIPS reporting periods, it’s not too late to get started. The thresholds for participation are still relatively low in 2019, so it’s a good time to become familiar with exactly what is required to, at a minimum, avoid a penalty in your 2021 payments. 


Learn more about Kareo Clinical, the 2015 Certified EHR designed specifically to help independent medical practices succeed. 

About the Author

Aimee Heckman is a Healthcare Business Consultant with more than 25 years of experience in Medical Practice Management, Revenue Cycle Management, PM/EHR...

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