In early September, the Centers for Medicare and Medicaid (CMS) announced the creation of a tiered approach to data reporting that will allow physicians more flexibility in the first year of Medicare’s new payment program under the Medicare Access and CHIP Reauthorization Act, commonly called MACRA.
Under the tiered approach, for the Quality Payment Program (QPP), providers will be allowed to choose the level and pace at which they will report pursuant to the new payment reform models that will go into effect in 2019. This recent development comes as a result of intense pressure from industry stakeholders, policymakers, and medical associations asking CMS to ease implementation and provide alternatives and greater support in transitioning to the new models— especially for solo and small practice providers.
Below are the four options qualifying providers may select from in order to begin participating for the first performance period, scheduled to begin January 1, 2017. Selecting an option is important to ensure that a practitioner is not penalized in 2019.
Option 1— Test the QPP: Physicians currently in the Merit-Based Incentive Payment System (MIPS) will avoid a 2019 penalty by reporting “some” quality and cost data. As long as some data are submitted, including data from after January 1, 2017, there will be no negative payment adjustment in 2019. This option is intended to ensure the physician’s system is working and prepares the practice for broader participation in 2018 and 2019. The word “some” is yet undefined, though there should be more clarity in the final rule scheduled to be announced November 1.
Option 2—Participate for Part of the Year: Physicians in MIPS can submit quality and cost data for just part of 2017 and the performance period can begin after January 1, 2017. This option will not only avoid a negative payment adjustment (penalty) but could qualify the physician for a small positive payment adjustment (bonus) in 2019. To get in better position for the bonus, reporting should consist of submitting both information on quality measures and improvement activities.
Option 3—Participate for the Full Calendar Year: This is for physicians who are ready to go on January 1, 2017, and choose to submit Quality Payment Program information for a full calendar year. This option would also qualify physicians for a modest positive payment adjustment in 2019.
Option 4—Participate in an Advanced Alternative Payment Model (APM) in 2017: This option has been available all along and will continue to be so under the new models. For solo and small group practices, however, this may not be a viable option at this time as it entails joining a larger cohort in order to maximize benefits. If a physician currently participates in the Medicare Shared Saving Track 2 or 3 and continues to do so in 2017, he or she would be exempted from quality data reporting. More details will become available for APM options upon the announcement of the new rules on November 1.
Whichever option a physician selects, participation in some form will avoid the likelihood of sustaining penalties in 2019 and increase both the necessary practice and experience within the new models to maximize the potential for bonuses.
CAP will continue to highlight outcomes from the final ruling released on October 14, 2016.
This information should not be considered legal advice applicable to a specific situation. Legal guidance for individual matters should be obtained from a retained attorney.