1/20/2017 | RESOURCES
With the start of the New Year, the first performance period for the Quality Payment Program (QPP), has officially started. The QPP, part of the MACRA legislation, was passed with strong bi-partisan support in Congress and sends a clear signal of the Federal Government’s accelerating effort to move to value-based payments. QPP creates two new tracks for Eligible Clinicians (ECs), as program participants are called: the Merit-based Incentive Payment System (MIPS) and the Alternative Payment Models Incentive Program.
MIPS consolidates and sunsets three programs focused on ambulatory providers: the Physician Quality Reporting Program, the Value-Based Payment Modifier, and the Medicare EHR Incentive Program for eligible professionals. In 2017, ECs can receive a maximum payment adjustment of plus or minus 4% based on their performance in four categories. ECs who are new to Medicare or who bill less than $30,000 or see less than 100 Medicare beneficiaries during a year will be exempt from MIPS.
In response to significant feedback from the provider community, the Centers for Medicare and Medicaid Services (CMS) has simplified the requirements and made 2017 a transition year to help ECs get used to participating in MIPS. Providers have three general approaches they can take:
Alternative Payment Models Incentive Program
The second track of QPP is focused on increasing EC participation in Alternative Payment Models (APM) (i.e. Accountable Care Organizations, bundled payments, etc.) by offering a 5% bonus and exemption from MIPS for ECs who participate in an Advanced APM and meet certain participation thresholds. In 2017, ECs must have at least 25% of their Medicare payments or 20% of their Medicare patient panel in a CMS Advanced APM to receive the bonus and MIPS exemption. ECs who meet lower payment or patient thresholds have the option to be exempt from MIPS. CMS maintains the list of qualifying Advanced APMs here.
The overarching framework created in the legislation and initial rulemaking completed by the Obama Administration will continue unchanged in 2017. The Trump Administration will have a chance to put its own twist on the QPP in 2017 by filling in the program implementation details through sub-regulatory guidance (much like CMS has done with the Meaningful Use program) and in 2018 and beyond through rulemaking to establish future program requirements. If Representative Tom Price is confirmed as the Secretary of the Department of Health and Human Services he may accelerate efforts to reduce provider burden and simplify the QPP.
As providers prepare to participate in the first year of QPP and HIOs prepare to support providers’ success, they should keep the following in mind.
A number of the improvement activities can be supported by HIOs. For example “Ensure that there is bilateral exchange of necessary patient information to guide patient care that could include one or more of the following: Participate in a Health Information Exchange if available; and/or use structured referral notes.” A key consideration for supporting improvement activities is whether the HIO has the ability to provide ECs with necessary audit documentation.