September 1st, 2017
- Low-Volume Threshold (LVT) - While ACA supports a low-volume threshold to exclude small practices, we oppose increasing the current LVT to the proposed levels because it would virtually eliminate chiropractors from Merit-based Incentive Payment System (MIPS) participation. Additionally, ACA encouraged CMS to allow clinicians who would be excluded by the LVT the ability to opt-in if they so choose.
- Virtual Groups - ACA commended CMS for further developing the concept of virtual groups (i.e., groups established among small practices, possibly separated geographically to further encourage participation in MIPS), however, most small practices that would participate in MIPS via virtual groups would be excluded due to the LVT. ACA encouraged CMS to allow small practices to opt-in to MIPS via virtual groups regardless of their exclusionary status due to the LVT.
- Submission Mechanisms - ACA is encouraged by CMS proposal to allow clinicians to submit through multiple submission mechanisms. This provides clinicians with the flexibility they need to submit meaningful measures.
- Measures and Scoring - ACA voiced several concerns over the proposals for Quality, Cost, Improvement Activities and Advancing Care Information categories. Most notably, DCs are at a disadvantage when reporting measures because they are limited to only reporting three CPT codes. ACA encouraged CMS to expand the billable codes allowed for chiropractors so that could participate in MIPS in a more meaningful way. ACA also commended CMS for proposing to establish a clear exclusion for e-Prescribing, as well as continuing to offer hardship exclusions for Advancing Care Information measures.