Medicare Access and SHIP Reauthorization Act of 2015
Merit Based Incentive Payment System
Advanced Alternative Payment Models
Quality Payment Program
The Centers for Medicare & Medicaid Services (CMS) released the final rule that will implement Quality Payment Program (QPP) as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Although QPP begins January 1, 2017, the first 2 years of the program there will be less financial risk. Allowing for providers time to navigate the requirements.
The Program has two paths for participation:
Best way to get ready for QPP, MACRA, MIPS (Merit Based Incentive Payment System) is to satisfy Meaningful Use Stage 2 (MU2) requirements and continue to work on meeting Clinical Quality Measures (CQM). CMS states providers already attesting to MU2 + PQRS will likely not have any new requirements.
Although the QPP will still begin January 1 2017, there will be a ramp-up period with less financial risk for eligible clinicians in at least the first two years of the program. Given the wide diversity of clinical practices, the initial development period of the QPP implementation would allow clinicians to pick their pace of participation for the QPP’s first performance period that begins January 1, 2017. As described by CMS in the final rule.
Providers who have not signed up with a registry should do so now because they will need to report data to the registry. There are registries that are specialty specific, so check with your medical association for more information, specific to you and the state you are located in.
Continue to follow MU2 and CQM guidelines. You will have to report at least 3 of 6 NQS areas. The 6 NQS areas are:
A list of all measures can be found here.
CMS estimates that over 90% of MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment in the transition year, and that at least 80% of clinicians in small and solo practices with 1-9 clinicians will receive a positive or neutral MIPS payment adjustment.
After calculating a MIPS score, eligible professionals (EPs) may receive a payment bonus, a payment penalty or no payment adjustment. Unlike previous payment programs, scoring is no longer all-or-nothing but rather proportional to performance.
The proposed MIPS score will be based on four performance categories as follows:
The weight of each category will shift over time so that cost measures are a higher percentage of the MIPS score.
|Performance Category||Points Needed to Get a Full Score per Performance Category||Category Percentage of MIPS Total Score|
|Quality||Clinicians choose six measures to report to CMS that best reflect their practice. One of these measures must be an outcome measure or a high quality measure and one must be a crosscutting measure. Clinicians also can choose to report a specialty measure set.||80 to 90 points depending on group size||50%|
|Advancing Care Information||Clinicians will report key measures of interoperability and information exchange. Clinicians are rewarded for their performance on measures that matter most to them.||100 Points||25%|
|Clinical Practice Improvement Activities||Clinicians can choose the activities best suited for their practice; the rule proposes over 90 activities from which to choose. Clinicians participating in medical homes earn full credit in this category, and those participating in Advanced APMs will earn at least half credit.||60 Points||15%|
|Cost||CMS will calculate these measures based on claims and availability of sufficient volume. Clinicians do not need to report anything.||Average score of all resource measures that can be attributed.||10%|
*These total percentages generally apply, but possible exemptions or adjustments may apply depending on a clinician or groups’ circumstances which would cause the total score for the category to be different.
Source: CMS Quality Payment Program
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation passed and RFI public comments submitted to CMS.
QPP Proposed and Final Rule released.
MIPS first performance year begins. Multiple reporting options for providers allow them to pick an option that works best for their practices. Options to avoid a negative payment adjustment include reporting some data, a 90 day reporting period, and a full year reporting period. MIPS payment adjustments in 2019 will be based on performance in 2017.
Providers who are ready to begin participating in the programs can start collecting performance data on Jan. 1, 2017 and could result in a positive payment adjustment. MIPS payment adjustments in 2019 will be based on performance in 2017.
Providers who are not yet prepared to participate have until Oct. 2, 2017, to begin collecting performance data and still could qualify for a small positive payment adjustment. MIPS payment adjustments in 2019 will be based on performance in 2017.
The performance period for MIPS is the full calendar year (Jan. 1 through Dec. 31) two years prior to the payment adjustment year. As such, MIPS payment adjustments in 2020 will be based on performance in 2019. 2018 reporting requirements are subject to change, and CMS will release more information in 2017.
Participating providers must submit all data, regardless of when collection began in 2017, to CMS by March 31, 2018.
MU, PQRS and VBM payment adjustments sunset for Medicare providers at the end of 2018.
MIPS Payment Adjustment (+/-) 4% plus up to a 12% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.
MIPS Payment Adjustment (+/-) 5% plus up to a 15% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.
MIPS Payment Adjustment (+/-) 7% plus up to a 21% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.
MIPS Payment Adjustment (+/-) 9% plus up to a 27% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.