One of the most significant requests from physicians upon the release of the Medicare Access and CHIP Reauthorization Act (MACRA) proposed rule was a transition period to enable participating practices to avoid a penalty during the implementation of the Quality Payment Program (QPP) created by the MACRA law. The Centers for Medicare and Medicaid Services (CMS) has included several measures in the final rule that grant a more flexible first year of the new program. The key: participation.
CMS has made the transition year quite simple when compared with previously implemented programs. The transition begins Jan. 1, and physicians will have four “pick your pace” options to avoid penalties in 2019. In addition to those options, CMS reduced the proposed calendar year reporting period for full participation to only 90 days.
Understanding the Merit-based Incentive Payment Program (MIPS) first requires a look at its four components. If participating in MIPS, as opposed to an Advanced Alternative Payment Model (APM), physicians earn a payment adjustment based on data reported in four categories. The following explanation reflects reporting after the transition year.
Quality. This component replaces the Physician Quality Reporting System (PQRS). Practices will report up to six quality measures, including at least one outcome measure, for a minimum of 90 days.
Improvement activities. This is a new category. Practices will attest that they completed up to four improvement activities for a minimum of 90 days. Small practices—those with 15 or fewer physicians—and medical groups in rural or health professional-shortage areas will only need to report one or two activities.
Advancing Care Information (ACI). This component replaces the burdensome EHR Meaningful Use program. Practices must fulfill the required measures—perform a security risk analysis, prescribe electronically, provide patient access to information, send a care summary, and request and accept a care summary—for a minimum of 90 days. You can also choose to submit up to nine performance measures to achieve full ACI credit. If these measures do not apply to your practice, you may not need to submit for this component.
Cost. This component replaces the Value-based Modifier, but will not begin until the 2018 reporting year. No data reporting is required for this component because it will be calculated from claims.
From size and location to the types of patients treated, not all practices are the same, physicians told CMS during the comment period on the MACRA proposed rule. CMS listened, and has created four options to focus the initial year of the program on encouraging participation and making sure physicians understand and are ready for full participation in the years to come.
If you participate in one of the following options, your practice will not receive a penalty in 2019. If your practice chooses not to take part, there will be a 4 percent pay cut.
MIPS testing. If your practice feels unprepared or would like to test the program, this is the option to take. Practices can choose to report one quality measure, one improvement activity or four required ACI measures at any point in 2017 to demonstrate capability. There is no minimum reporting period and your practice will not receive a penalty in 2019.
Partial MIPS reporting. This option takes reporting one step further. Practices can choose to report more than one quality measure, more than one improvement activity or four required ACI measures for at least 90 consecutive days in 2017. Participation guarantees no penalty, but this option provides the potential for a bonus of less than 4 percent in 2019.
Full MIPS reporting. If your practice is ready to participate in the full MIPS program, you can get started with this option. Practices may choose to report for at least 90 consecutive days. Your practice will avoid a penalty in 2019, but may be eligible for a bonus of up to 4 percent. Exceptional performers that report for the full year could land as much as a 10 percent pay bonus.
Advanced APM participation. Practices can instead choose to participate in Advanced APMs, which have their own reporting requirements and are exempt from MIPS. Physicians in advanced APMs who have enough Medicare patients and receive a sufficient portion of Medicare payments through the APM, will qualify for a 5 percent bonus incentive payment in 2019.
These options should allow all physicians who provide care to Medicare patients to participate in the transition year and avoid a penalty in 2019. Participating in 2017 will help your practice build the capabilities to report and gain experience with the QPP.
More resources and tools are provided by the AMA are available to help your practice navigate Medicare payment reform.