Even with all the proposed healthcare changes under the new administration, MACRA is not going away. Government agencies and payers are committed to value-based care and reimbursements.
CMS has branded the initiative the Quality Payment Program (QPP). Under the Quality Payment Program there are two tracks your practice can choose from – the Merit-Based Incentive Program (MIPS) and Advanced Alternative Payment Models (APMs).
The differences between the two include:
- MIPS: a more traditional Medicare program, the clinician’s score is based on four performance areas: Quality Measure Performance (replacing PQRS), Advancing Care Information (replacing MU), Cost (replacing value-based modifier) and Improvement Activities categories. The categories are weighted and will change over the course of a few years. Clinicians can receive a positive, negative or neutral adjustment and will be benchmarked against other clinicians.
- Advanced APM : you may earn an added incentive payment for participating in this model if you are providing high quality and cost-effective care. To be considered eligible, the APM must meet several criteria. The current models approved by CMS for 2017 are: Comprehensive ESRD Care (CEC) – Two-Sided Risk, Comprehensive Primary Care Plus (CPC+), Next Generation ACO Model, Shared Savings Program – Track 2, Shared Savings Program – Track 3, Oncology Care Model (OCM) – Two-Sided Risk, Comprehensive Care for Joint Replacement (CJR) Payment Model (Track 1- CEHRT) and Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model). Providers who are participating in other payment models are not eligible for the bonus in 2017, but are still required to report modified MIPS based on the APM.
Who are those eligible clinicians?
For reporting in 2017, eligible clinicians are defined as physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists. In the 2019 performance year, the category will expand to include physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists and dietitians/nutritional professionals.
What is the Performance Year?
Practices can begin collecting data from January 1, 2017 and can choose any 90-day period up to a full calendar year. The last 90-day period starts October 3rd, 2017. Reporting must be done by March 31, 2018. The first payment adjustments begin on January 1, 2019.
Why start collecting data before October 2, 2017?
By collecting data early, you can look at your performance rates as an individual and as a practice. With that data, you can make adjustments to your processes. By waiting until October 2nd, you have no opportunity to improve performance, and could see a negative adjustment to payments in 2019.
Do we have options for submitting data under MIPS?
CMS has created a plan called Pick Your Pace. The size of your payment adjustment will be determined by your performance with quality data.
- Submit a Full Year – you could earn a moderate positive payment adjustment (again, determined on your performance)
- Submit a Partial Year – you can choose to only submit 90 days (note the October 2nd deadline). With this plan you could earn a neutral or small positive payment adjustment
- Submit Something – you could submit a minimum amount of data, like one quality measure or one improvement activity. Submitting this helps you avoid a downward payment adjustment
- Do Not Participate – this is an automatic negative 4% payment adjustment
NOTE: Our Quality Reporting Engagement Group recommends reporting the entire year of data. Your practice will have the opportunity to review its performance during the year and make adjustments for improvement. You will also have the possibility of receiving that moderate positive payment adjustment.
This is the first of a series of articles on the Quality Payment Program. For additional questions or help with your reporting, email us at firstname.lastname@example.org or call 877-570-8721 x2.
For practices that already work with our program, we will work with you to maximize your potential score.