Contemplating my first post of the New Year, I found myself viewing a picture hanging on the wall in our home. The artist is not well known, but he is remarkably talented. As a result of an accident when he was 13 years old, Clayton Turner is a quadriplegic and, unable to use his hands, his sketches are all performed by holding the pen in his mouth. The title of the mouth sketch in our home is “Bad Hombres.” Staring at the three tough-looking amigos in the picture, it occurred to me that many things, both good and bad, come in threes. Take sports for example. Although football is arguably garnering most of the nation’s sporting attention these days, the hockey and European football (soccer) seasons are well underway, with players in hot pursuit of the elusive hat trick. The boys of summer have three strikes for every at bat. And let’s not forget basketball’s triple threat position (will he shoot, will he pass, or will he blow by me on the way to the rack?).
Last week, Diana highlighted a number of dates ahead of us in 2015, pointing out what a busy year it will be for nephrology practices. Building upon that fantastic post, this week let’s take a look at the CMS triple threat.
A little background
CMS is getting very serious about attracting your attention. They have substantially raised the stakes with respect to the penalties you will incur for non-participation in these programs. The penalties are additive, which means ignoring or failing to successful participate in this trifecta could result in a seven or nine percent reduction in your 2017 physician fee schedule. And let’s not forget, that’s on top of the two percent hit you are likely to face if the sequester remains intact. In most nephrology practices, the docs are the last folks to be paid, which means this will come right out of your pocket! Assuming you do not plan to retire between now and then, what can you do to avoid this double-digit haircut?
PQRS (-2%): Participation is the name of the game
Let’s start with the low hanging fruit. Failure to successfully satisfy the CMS PQRS reporting requirements in 2015 will cost you two percent in 2017. Of the three physician-facing CMS programs, PQRS is the easiest to understand, and it is the one I would encourage each of you to participate in. There are a myriad of ways to report PQRS in 2015 and we have recently reviewed those options for you. In fact, just a few months ago Diana provided a deeper dive into two of the popular options. Regardless of how you do it, don’t wait until the last minute to consider how you will successfully tackle PQRS in 2015.
VM (-2% or -4%): Again, participate in PQRS
The physician value-based payment modifier (thankfully shortened to VM) is the new kid on the block. We have also tackled this one in the Acumen blog before with a series of posts. In my experience this is the most complex member of the CMS trifecta. I have spent more time than I am willing to publicly admit studying this beast, and I will have the privilege of sharing some of those insights with those of you attending the upcoming RPA meeting. In the meantime let me share two important observations about the VM.
First, most practices will see neither penalty nor bonus from the VM and within its current construct, I think it will be very difficult to move the needle one way or the other. Second, and this one is very important, if your practice is not successful reporting PQRS in 2015, you will get tagged with the maximum VM penalty. That’s a two percent hit in 2017 if you work in a practice with nine or fewer providers and a four percent 2017 penalty if your practice has 10 or more providers. Remember these penalties are additive. Stated another way, missing the mark for PQRS in 2015 will cost you four or six percent of your Part B book of business in 2017.
Meaningful Use (-3%): Hope for a hardship exemption
Saving the best for last does not apply to today’s post, as MU is easily the most frustrating member of the CMS triple threat. Unfortunately the architects of the MU program created a framework in which successfully meeting the targets becomes more difficult over time, while concurrently you are paid less or face rising penalties as the work you do is harder to accomplish. Adding insult to injury is the fact that this program is squarely aimed at primary care providers, making it even more challenging for nephrologists providing care in places like a dialysis facility or a vascular access center.
This year over 250,000 providers are facing a one percent penalty for not demonstrating MU in 2013. That number will certainly climb in the years ahead. There is a growing wave of discontent across the country related to the MU program, which was well summarized in an article a colleague recently shared with me. Of course things do not move quickly within the beltway so I would not wait on Congress for a reprieve. If there is a silver lining for nephrologists in all of this, perhaps it can be found in the MU hardship exceptions. A large number of nephrologists are rightfully filing for the 50% rule hardship as most of their encounters occur in a dialysis facility or vascular access center, venues of care that were never intended to be part of the program.
As a fan of both sports and numbers, I can tell you it is the number zero which historically provides the most intrigue, and a goose egg is well positioned within the context of the CMS triple threat. Imagine for a moment if in 2015 your practice successfully reports PQRS and you successfully file for a MU hardship exception. The odds are very much in your favor that you will not face a Part B fee schedule reduction in 2017. And in the words of the late Stuart Scott, that’s “cooler than the other side of the pillow.” With the unusual backdrop of inspiring artists and sports broadcasters, I hope that 2015 is indeed a Happy New Year for you and for your practice. All it will take is a little planning.
Terry Ketchersid, MD, MBA, practiced nephrology for 15 years before spending the past seven years at Acumen focused on the Health IT needs of nephrologists. He currently holds the position of Chief Medical Officer for the Integrated Care Group at Fresenius Medical Care North America where he leverages his passion for Health IT to problem solve the coordination of care for the complex patient population served by the enterprise.