Small Practices - Wondering What To Do Now Medicare Quality Payment Program (QPP) Regulations Have Been Issued

Now that the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) regulations have been issued, small practices (15 fewer clinicians) need to immediately know what to do to prepare for the beginning of 2017.


Medicare’s new low volume threshold makes it paramount to determine whether or not you are subject to the Medicare Quality Payment Program. Extensive preparations need to take place over the next few months to avoid a possible reduction in Medicare compensation for 2019, if you are subject to the QPP.


The new low volume threshold is set at:

  • less than or equal to $30,000 in Medicare Part B allowed charges; or

  • less than or equal to 100 Medicare patients.


Top Four Take Aways:

  1. Early on, don’t expect to rely on Medicare (CMS) to give you the nod as to whether you are subject to the QPP or not. CMS has indicated, that it may do so near the start of the program (i.e. Dec 2016). For some, this may be too late to adequately prepare.

  2. In order to perform the calculation, CMS has indicated that for the 2019 Merit-based Incentive Payment System, will initially identify the low-volume status of individual eligible clinicians and groups based on 12 months of data starting from September 1, 2015 to August 31, 2016.

  3. If you find that you are clearly above the low volume threshold, you are in the QPP. If you are close to the threshold, take into considerations current and future changes to your practice in determining whether or not to participate and at what pace in year one (2017).

  4. Calculate your financial risk:

  • What is the internal cost to conform to QPP provisions?

  • What are the costs of not conform to QPP provisions?

Medicare has taken strides to make it easier for small practices to ease into the QPP, but there is still a lot to consider. Do you have questions about how small practices will be affected under the Medicare Quality Payment Program?  Comment below and we will dive into them and other MACRA and QPP issues facing small practices. 

Miss any of our previous MACRA blogs?

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About Our Industry Expert and Author:

Kerry Luciani



Kerry has over 30 years of healthcare revenue cycle management experience on both the payer and provider side. Over the course of his career, Kerry has developed an abundance of expertise in Medicare Part B reimbursement and has published several comments in the Federal Register.