DEPARTMENTS: PRACTICE POINTS
Welcome to 2017! This new year brings our focus to the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment period to implement MACRA’s new Quality Payment Program (QPP). The MACRA repeals the Medicare Part B Sustainable Growth Rate reimbursement formula and replaces it with a new value-based reimbursement system—QPP. The QPP consists of 2 major tracks:
- The Merit-Based Incentive Payment System (MIPS): https://qpp.cms.gov/learn/qpp
- Advanced Alternative Payment Models (Advanced APMs): https://qpp.cms.gov/learn/apms
In this column, we will focus on MIPS. The following content includes direct excerpts from the QPP (https://qpp.cms.gov) and its Executive Summary document (https://qpp.cms.gov/docs/QPP_Executive_Summary_of_Final_Rule.pdf).
You are a part of the QPP in CY2017 if you are in an Advanced APM or if you bill Medicare more than $30,000 a year and provide care for more than 100 Medicare patients a year. You must meet both the minimum billing and the number of patients to be in the program. If you are below either requirement, you are not in the program.
For MIPS, you must also be a physician, physician assistant, nurse practitioner, clinical nurse specialist, or certified registered nurse anesthetist. The specific Medicare-enrolled clinicians excluded from MIPS include newly Medicare-enrolled MIPS-eligible clinicians, qualifying APM participants (QPs), certain partial QPs, and clinicians who fall under the finalized low-volume threshold.
You get to pick your pace for the QPP (see Pick Your Pace in MIPS). If you’re ready, you can begin January 1, 2017, and start collecting your performance data, or you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you will need to send in your performance data by March 31, 2018. Remember, the first payment adjustments, based on performance, go into effect on January 1, 2019. You can also begin participating in an Advanced APM.
The eligible clinician (EC) can earn a payment adjustment based on evidence-based and practice-specific quality data contributing to an annual MIPS final score of up to 100 points. The EC needs to demonstrate high-quality, efficient care supported by technology by sending in information in the following categories:
- Quality (formerly Physician Quality Reporting System) accounts for 60% within CY2017.
- Advancing care information (formerly Meaningful Use) accounts for 25% within CY2017.
- Clinical practice improvement activities (referred to as “improvement activities”) accounts for 15% within CY2017.
- Resource use (referred to as “cost”) accounts for 0% within CY2017.
The final score earned by an EC for a given performance year then determines MIPS payment adjustments in the second calendar year after the performance year.
The program begins in 2017 and payment adjustments begin in 2019. Eligible clinicians can “pick their pace of participation” during the 2017 transition year to avoid a negative payment adjustment in 2019:
- Option 1: Test/submit something. If you submit a minimum amount of 2017 data to Medicare (eg, 1 quality measure or 1 improvement activity for any point in 2017), then you can avoid a downward payment adjustment.
- Option 2: Partial/submit a partial year. If you submit 90 days of 2017 data to Medicare, you may earn a neutral or positive payment adjustment.
- Option 3: Full reporting. If you submit a full year of 2017 data to Medicare, you may earn a positive payment adjustment.
- Not participating in the QPP. If the EC does not send in any 2017 data, he/she receives a negative 4% payment adjustment (unless he/she falls under one of the exemptions).
Reporting as an individual. If the EC sends in MIPS data as an individual, the payment adjustment will be based on the EC’s performance. An individual is defined as a single national provider identifier tied to a single taxpayer identification number. The EC will send his/her individual data for each of the MIPS categories through an electronic health record, registry, or a qualified clinical data registry, or send in quality data through routine Medicare claims process.
Reporting as a group. If the ECs send MIPS data with a group, the group will get 1 payment adjustment based on the group’s performance. A group is defined as a set of clinicians (identified by their national provider identifiers) sharing a common taxpayer identification number, no matter the specialty or practice site. The EC’s group will send in group-level data for each of the MIPS categories through the CMS web interface or an electronic health record, registry, or a qualified clinical data registry; groups must register by June 30, 2017.