CMS also addressed physician criticism regarding the low-volume exemption, which excludes otherwise-eligible physicians and groups from participating in MIPS if they meet the low-volume threshold. The threshold amount, as established in the 2017 QPP rule, is no more than $30,000 in Medicare Part B allowed charges annually, or 100 Medicare patients treated.
Like many other groups, the AACU emphasized that the current threshold amount is insufficient and urged CMS to either raise the threshold amounts or associate the threshold with actual practice size so exemptions are appropriately applied and small practices are not burdened to the point of closure. CMS responded by proposing to raise the threshold amount in 2018 to no more than $90,000 in Part B charges annually, or 200 Medicare patients treated.
While this is undoubtedly an improvement, there is still significant concern that even the increased low-volume threshold is still too low for most urologists in solo or small practices. Since urologists see, on average, a greater number of Medicare patients than other types of physicians, the AACU recently urged CMS to consider increasing the low-volume threshold even more than is currently proposed, or at the least to gather urology-specific data on this exemption and analyze its effect on urologists and other specialty physicians.
Better, but still a long way to go
All in all, there were significant improvements in the 2018 proposed rule, and it is impossible to deny that CMS made an effort to truly consider feedback from physicians and the health care community by incorporating suggestions for improvement in year two of the QPP. But there are still substantial problems with QPP implementation that will continue to burden urologists treating Medicare patients.
Moreover, the underlying fundamental issue with QPP and its implementation still remains: numerous and fragmented compliance requirements and complex scoring mechanisms are not only difficult for providers to understand, but have also proven to be near impossible for providers to practically integrate and fully implement. And despite CMS’s best efforts, a 1,058-page proposal does very little to help that.
But urologists should not give up hope. CMS has proven that it is willing to work with providers by listening and working with them to address their complaints and reduce administrative burdens. The proposal for 2018 is an improvement on 2017 QPP policies, and as long as physicians continue to voice their concerns and engage with CMS, understanding and complying with MACRA may start to get easier.