In an effort to move away from fee-for-service payments and put more emphasis on quality of care, CMS unveiled the new Quality Payment Program under The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The program’s goal is to improve reporting and ultimately change the way clinicians are paid for their services under Medicare. Quantity can no longer be the driver when quality is the sacrifice to getting there. The new QPP is a major step in improving care across the entire healthcare system.
Back to basics
Participation in the QPP program is gained through the physician’s choice of one of two pathways: the Merit based Incentive Payment Program (MIPS), which combines the previous PQRS the Value-based Modifier and Meaningful Use programs or the Alternative Payment Model (APM). The path they choose will depend upon their practice size, specialty, location, or patient population. Eligible participants are those clinicians who report Medicare services in the amount of $30,000 and care for 100+ Medicare patients per year.
What does that mean for my practice?
The new program brings a list of tasks for those who prepare to participate. If you’ve determined that your practice is MIPS-eligible, through either a letter received from CMS or by using the CMS MIPS eligibility determination look up tool, you’ll need to implement an action plan that will allow you to submit some or all of your data during the first quarter of 2018—or be subject to a 4% penalty.
Between now and then, you’ll need to review the available performance categories and components, “pick your pace” for participation, identify and implement your reporting mechanism, and finally, review and submit your data before the deadline.
Performance categories: Quality, Advancing Care Information (ACI), and Improvement Activities (IA) are the categories available to describe performance for the 2017 year. It’s important to consider which components will help you successfully reach your 2017 reporting requirements.
Under the Quality category, you’ll need to choose six measures on which to report. You’ll need to have completed 4 activities over a period of 90 days under the Improvement Activities category, and the Advancing Care Information category will require at least five qualifying measures with the option to submit others for additional credit.
“Pick your pace”: During the transition year, you have the ability to “pick your pace,” which allows you to choose whether all, a portion, or none of your data will be reported for 2017. You could have started reporting as early as January 1 or as late as October 2, 2017. If you submit a full year of data for 2017, you may earn a positive payment adjustment. If you submit at least 90 days of data, you may earn a neutral or positive payment adjustment. Even if you submit the minimum amount of data to Medicare, you may still be able to earn a positive payment adjustment. Any payment adjustment is determined by the data submitted, not the length of time it encompasses.
Reporting mechanisms: Will you report as an individual or as a group? Which reporting mechanism will best fit the needs of your practice? Are you working with an EHR vendor? If you’re currently using a vendor, ensure their product will be upgraded to meet your MIPS reporting needs.
What if I miss the October 2nd deadline?
The deadline to begin gathering data to send to Medicare is October 2, 2017. If you’re unable to send the minimum 90-day reporting, your practice will be subject to a 4% penalty.
If your office is MIPS-eligible, it’s critical for you to educate your office staff about MIPS, how performance will be evaluated, and how it will affect your Medicare payments beginning in 2019. Completing your preparation before the October 2nd deadline must be a group effort. When everyone is up-to-date on legislation, is aware of the progress, and understands the repercussions, the process will run much more smoothly.