The initial choice for many radiologists with regard to MACRA and its MIPS program will be what to do with their gap year. Practices with 15 or fewer physicians—almost a third of all U.S. physicians—are excluded, but CMS expects to widen the net in future rulemaking.
All other practices will have the option of taking a “transitional year” with partial participation as they ramp up their ability to comply. “Nonpatient-facing” hospital-based practices will have the option to exempt themselves from complying with the IT component of MIPS.
Small radiology practices will be faced with difficult decisions ahead, as market forces and government regulations converge to promote the development of larger and more sophisticated physician organizations with the resources to manage compliance.
Compliance in medicine today is somewhat less complicated than brain surgery (I’m guessing), but a good deal more complex than operating almost any other type of business. With local, state, and federal regulatory agencies issuing continual compliance and performance standards, small practices will need to be very resourceful to maintain the small, collegial model and survive.
The challenge with MACRA for every physician practice, large and small, will be to review the many options for participation, find those that may actually do what they are intended to do—improve quality and reduce cost—and then devise the most efficient way to demonstrate compliance.
To all practices with 15 or fewer physicians whose members are inclined to put their heads down, churn out studies, and fatten their 401Ks, that would be a very short-sighted approach to the gap year. Playing catch up once the train has left the station could very well prove impossible.