CMS published a fact sheet detailing the flexibility and support built into the proposed rule for the Medicare Access and CHIP Reauthorization Act for physician practices of 15 or fewer providers.
The fact sheet comes in response to an impact analysis that fueled concerns the proposed rule would negatively impact smaller practices. The agency contends that the analysis was based on data that did not include many small or solo practices and that it did not reflect the accommodations proposed for such practices.
Here is a brief overview of the accommodations highlighted in the report.
1. One of the two paths available in the proposed rule, the Merit-based Incentive Payment System, streamlines several CMS quality programs and adjusts payments based on performance in four categories. In addition to specific flexibilities within each of the performance categories, small practices are accommodated under MIPS in the following ways:
- Practices with low Medicare volume — defined as $10,000 or less in Medicare charges and 100 or less Medicare patients — are excluded from the MIPS payment adjustment.
- If a practice does not have sufficient measures or applicable activities in a MIPS performance category, that category will not be included in the overall MIPS score, which determines the payment adjustment a practice receives.
- Individual physicians have the option to combine and report as a "virtual group."
- Practices can submit a single report for the Quality, Advancing Care Information and Clinical Practice Improvement Activities, and they do not need to report in the cost performance category.
2. The other available path, Advanced Alternative Payment Model, awards physicians in qualifying care delivery models with lump-sum payments from 2019 to 2024, with a favorable payment update beginning in 2026. CMS accommodates small practices under APM in the following ways:
- Special rules apply to small or rural practices, or those in healthcare professional shortage areas, for medical home alternative payment models.
- These rules would include unique financial risk standards for medical homes with 50 or fewer physicians.
3. Education, training and technical assistance will be available to help onboard physicians with the MACRA programs. CMS plans to support small practices through the following outreach efforts:
- CMS will provide $100 million of technical assistance over five years.
- Twenty-nine practice transformation networks will be established to provide peer-level support to physicians.
- Ten support and alignment networks will help create specialty-specific collaboratives to support physicians in the care transition.
- CMS will also establish a Health Care Payment Learning and Action Network as a forum for small practices and other organizations to discuss, track and share best practices on the value-based care transition.
The proposal is open for comment until June 27. Comments may be submitted here.
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