Andy Slavitt, the Acting Administrator of the Centers for Medicare and Medicaid Services (CMS), recently published a detailed blog post outlining the Quality Payment Program (QPP). QPP is slated to begin January 1, 2017. If you are unfamiliar with QPP, let’s back up a bit. In 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) was signed into law to replace the previous Medicare reimbursement schedule to a new pay-for-performance program that’s focused on quality and accountability. This program from the Centers for Medicare and Medicaid Services (CMS) is proposed to offer an incentive program to focus on quality of care as opposed to volume.
Fast-forward now to January 1, 2017 where the Quality Payment Program will replace the Sustainable Growth Rate Formula for all Medicare Part B providers. According to the Centers for Medicare and Medicaid Services, this single framework program has two paths of incentives for providers: The Merit-based Incentive Payment System (MIPS), and the Advanced Alternative Payment Models (APMs). With the Quality Payment Program set to begin January 1, 2017, Slavitt addresses options regarding the timing of reporting for the first year of the program. The different options keep in mind the diversity of various provider practices. The Centers for Medicare and Medicaid Services intend for the Quality Payment Program to allow the providers to select their individual pace of participation for the first period beginning January 1, 2017.
The following pacing options are directly from Andy Slavitt’s blog:
First Option: Test the Quality Payment Program
With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment. This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.
Second Option: Participate for part of the calendar year
You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than January 1, 2017 and your practice could still qualify for a small positive payment adjustment. For example, if you submit information for part of the calendar year for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a small positive payment adjustment. You could select from the list of quality measures and improvement activities available under the Quality Payment Program.
Third Option: Participate for the full calendar year
For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on January 1, 2017. For example, if you submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a modest positive payment adjustment. We’ve seen physician practices of all sizes successfully submit a full year’s quality data, and expect many will be ready to do so.
Fourth Option: Participate in an Advanced Alternative Payment Model in 2017
Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.”
These options are available to eligible physicians and other clinicians during 2017. Providers must participate in one of the options in order to avoid a negative payment adjustment in 2019.
Slavitt concludes his blog by ensuring providers with the following statement; “However you choose to participate in 2017, we will have resources available to assist you and walk you through what needs to be done. And however you choose to participate, your feedback will be invaluable to building this program for the long term to achieve outcomes that matter to your patients.”