While the first year of MACRA reporting is already drawing to a close, healthcare providers are weighing clarification on special status groupings from the Centers for Medicare and Medicaid Services that affect how they report, or whether they have to report at all.
The special statuses were introduced to give clinicians more flexibility in reporting and can mean you have to do less reporting, can avoid certain categories and/or focus on others more suitable to your capabilities.
There are five categories of special statuses and there's a lot of nuance there, but essentially the special statuses are about what the ultimate requirements are going to be for you when you participate in MIPS, said Ye Hoffman, research consultant for the Advisory Board. Calculations that determine whether you are a special status clinician are based on Medicare Part B claims data.
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The categories include: small practices, which are groups with 15 or fewer clinicians; non-patient facing, which is where the clinician has 100 or fewer Medicare Part B patient-facing encounters during the non-patient facing determination period; Health Professional Shortage Areas, or HPSA clinicians; Rural status, which includes practices in zip codes with the rural designation; and hospital-based clinicians who render 75 percent of their covered services in the inpatient hospital, on-campus outpatient hospital or emergency department setting during the determination period.
Special status also confirms who the hospital-based providers are that don't have to report on the meaningful use category for MIPS, Hoffman said, because from the MIPS perspective CMS acknowledges that MIPS and MU-like measures in MIPS are mostly applicable to ambulatory providers.
Say you're a hospital based in MIPS, CMS may say that the ACI category is not applicable to you so you don't have to report those measures. However, it is important to remember that it has nothing to do with whether your hospital reports meaningful use.
One area where Hoffman said providers are looking for more from CMS is educating beyond the initial determination of special status. She said their members are seeking more information on how providers apply their special status to their MIPS reporting strategy.
"It does take a certain level of expertise in what the requirements are in order to translate that into something actionable, so just knowing that you are a special status doesn't lead you to understand how it affects your MIPS reporting. That's the type of education that we encourage and expect to see more of as CMS gets questions from providers."
Jennifer McLaughlin, senior associate director of government affairs at the Medical Group Management Association agreed, saying their calculation tool needs to take things a step further.
"From what we've seen when our members go in and plug in their Medicare identifier, if they do get a notice that they do have a special status saying that they are considered a small practice in 2017, there's not been clear information for them about what that means or how that impacts their MIPS score or what their requirements are."
To navigate the process successfully, Hoffman made a few suggestions. Most important is to understand the MIPS requirements. It is a transition year, so the requirements are flexible and it's pretty easy to avoid the future penalties.
"We encourage providers to hit the ground running. Use this year as a learning year and ask questions."
Also, the 2018 proposal is out there and open for public comment so for any policies that are unclear, it is important to submit comment and ask for clarification
Start with CMS's Quality Payment Program website, which has valuable educational materials in formats like web conferences and fact sheets. You can also email or call the QPP help desk. Figure out if you are eligible or have to participate at all, and then that's when special status comes in. Along with that, you need to determine if you are going to participate in MIPS as an individual or as a group.
"For most reporting mechanisms you don't have to report a full year of data. So if you were waiting for this info before starting to nail down your strategy then you've got the rest of the year to look at your data and input this data into your calculations."