CMS Finalizes Medicare’s New Quality Payment Program

ABC will undertake a thorough review and analysis of the final regulations and provide guidance to ABC members for complying with the new payment system.
 

Today, October 14, the Centers for Medicare and Medicaid Services (CMS) issued a Final Rule that sets forth the guidelines for clinician participation in Medicare’s new Quality Payment Program (QPP).  The QPP was created under the Medicare Access and CHIP Reauthorization Act (MACRA) and provides one of two payment pathways for clinicians: the Merit-Based Payment Incentive Program (MIPS) or Advanced Alternative Payment Models (APMs). Clinicians will need to participate in one of the two pathways in 2017 to avoid a negative payment adjustment in 2019.
 
CMS heard the concerns of stakeholders during the MACRA comment period, and included additional flexibilities in the initial years of the QPP with the primary goal of encouraging participation.
 
Pick Your Pace of Participation
 
As CMS revealed in September, the final rule allows clinicians to “pick their pace” during the 2017 performance year to avoid a payment penalty.
 
Clinicians will be exempt from a payment penalty in 2019 if they choose any one of the following four options:
 
1)  Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize their chances to qualify for a positive adjustment. MIPS eligible clinicians who are exceptional performers, as shown by the practice information they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
 
2)  Clinicians can choose to report to MIPS for a period of time less than the full year 2017 performance period (but for a full 90-day period at a minimum) and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.
 
3)  The simplest way for clinicians to avoid a negative payment adjustment in 2019 is if they report any information.  This could include one measure in the quality performance category; one activity in the improvement activities performance category; or all the required measures of the advancing care information performance category. If a MIPS eligible clinician does not report one measure or activity, they will receive the full negative 4 percent adjustment in 2019.
 
4)  MIPS eligible clinicians can participate in Advanced APMs, and if they receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM they will qualify for a 5 percent bonus incentive payment in 2019.
 
The 90-day reporting period can occur anytime between January 1 and October 2, 2017.  All performance data must be submitted to CMS by March 31, 2018.  Clinicians can improve their chances of getting an additional positive payment adjustment by reporting more data from which performance will be assessed.

Merit-Based Incentive Payment System
 
CMS estimates that the vast majority of eligible clinicians will participate in MIPS. In fact, CMS estimates that only between 30,000-90,000 eligible clinicians will be qualified APM participants in 2017.
 
MIPS eligible clinicians will have their performance assessed under four categories: 1) Quality; 2) Resource Use; 3) Clinical Practice Improvement Activities (CPIAs); and 4) Advancing Care Information (formerly EHR Meaningful Use).
 
One of the most notable changes in the Final Rule is that for the initial MIPS year, the Resource Category will not be scored, although resource use information will still be collected from administrative claims data. The performance categories for 2019 scoring will be weighted as follows:
           
            — Quality = 60%
            — Resource Use = 0%
            — Clinical Practice Improvement Activities = 15%
            — Advancing Care Information = 25%
 
Medicare-enrolled clinicians who will be excluded from MIPS include newly Medicare-enrolled MIPS eligible clinicians, Advanced APM Qualified Participants (QPs), certain partial QPs, and clinicians who fall under the low-volume threshold. CMS has finalized the low-volume threshold as clinicians who have less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients.
 
Additional CMS Resources

QPP Overview Fact Sheet

QPP website