8-Part Series for Radiologists:
Protecting your Medicare Revenue Stream in 2017-2018
Part 7: What if I Do Nothing?
In Part 2 and 3 we covered how to determine if you qualify for the Medicare Quality Payment Program (QPP) or not. We will divide the discussion between those who do NOT quality under MACRA for the QPP versus those that do.
Revenue Impact for the Non-qualifying Radiologists under the Quality Payment Program (QPP)
If you have determined that you definitely are excluded, then you have two choices:
- Do nothing, and take the annual 0.5% Medicare fee increase (which ends in 2019), or
- Determine if it would be cost-effective to submit data under the Merit Incentive-based Payment System (MIPS). This could potentially earn you a bonus of up to 4% increase in your fees in 2019 increasing to 9% in 2022.
Let's look at the two options graphically based on a baseline of $100,000 in Medicare Fees.
Based on $100.000 in Medicare fees, the graph shows the baseline fees for the non-participating, non-qualifying physician in light blue. The dark blue bars show the difference in fees due to the potential for 4-9% bonuses for electively submitting MIPS data for scoring. This teal line shows the cumulative differences between the two physicians is $43,648 over the 8 years. This is not an insignificant number if you are already doing practice improvements and can leverage your own efforts toward value-based patient care.
For those that like the actual numbers, the non-qualifying radiologist would expect $101,508 in Medicare reimbursements in 2024. A physician doing voluntary submission under MIPS could potentially earn $110,643 dollars for the same amount of work. This represents a difference of $9,136 between the two radiologists doing the same work. This is a 9% difference.
Revenue Impact for the Qualifying Radiologists under the Quality Payment Program (QPP)
If you are a radiologist who qualifies for the QPP under MACRA and not part of an alternative payment model (APM, see PART 3) then there is a larger impact when you submit data under MIPS vs. taking the penalty for non-submission. The difference widens each year that you chose to not submit data and forego the potential bonus payments as shown graphically below:
From the second graph, we can see the accelerating difference in Medicare fees for potential bonuses vs. the full penalties. For two physicians receiving a baseline of $100,000 in Medicare reimbursement, the difference (shown in the teal line graph) is $87,296 over the 8 years.
For those of you who are less visually oriented, let me restate the impact between the two options. In 2024, the qualifying, but non-participating physician would earn $92,372. The qualifying, participating physician could earn up to $110,643 that year. The difference would be $18,271 on each $100,000 of Medicare revenue in today's dollars. That is an 18% difference. And there is no adjustment for inflation during those years, which at 2% per year for 7 years would add up as well.
Winners and Losers
The graph below shows the impact on three groups of physicians under the QPP relative to $100,000 in work. The green line shows the potential bonuses for submitting data. The black line shows the small increase given to those who do not quality for QPP. The red line reflects a reduction of fees by 4% in 2019, 5% in 2020, 7% in 2021 and 9% from 2022 and beyond.
But doesn't it just cost me too much money to comply with no guarantee of bonuses?
If you are a qualifying radiologist practice, you may feel like it may cost too much to comply with the QPP reporting. That is a fair concern. That is always a possibility when participating within a budget neutral program. However, there is one sure thing about the program. If you qualify and chose to not participate, you are committing your practice to declining Medicare fees for many years. Plus you will have the added erosion of inflation to your bottom line. So I recommend that you approach it with a different objective:
- The program will help me accelerate my practice from fee-for-service (volume-based) to value-based.
- The program will help approach quality and practice improvement activities from a data-driven approach.
- The program will help me to monitor and improve outcomes such as practice efficiency and patient satisfaction.
- And for my troubles, I may earn an additional bonus on my Medicare fees, while I avoid reduction.
If you are interested in a calculation of all the options, please email me at firstname.lastname@example.org and include your total Medicare fees for 2016. I will send you back a spreadsheet that you can use for your internal discussions and analysis.
The final part of this series will include links to additional resources and a list of frequently asked questions. I hope you now have a better understanding of how MACRA and PAMA potentially impact your Medicare reimbursement in the coming years.
If you missed
Part 1: Introduction, CLICK HERE.
Part 2: Details of MACRA and the QPP, CLICK HERE.
Part 3: How to Participate with QPP if You are a Radiologist Who Qualifies, CLICK HERE.
Part 4: Overview of PAMA and the Appropriate Use Criteria (AUC) for Imaging, CLICK HERE.
Part 5: More on PAMA and the AUC for Advanced Diagnostic Imaging, CLICK HERE.
Part 6: Preparing for MACRA, CLICK HERE.