January 04, 2017
CMS’ Quality Payment Program just got real. By now, most are aware that failure to meet CMS’ quality reporting standards could result in hefty penalties for practices. Last month, providers submitted challenges to the October final rule on MACRA. We are expecting an update later this month from CMS on modifications to the final rule.
CMS has responded to the healthcare community’s concerns by offering providers five options for Quality Payment Program participation, which began on Jan. 1 for the performance calendar year 2017. Participation in 2017 will impact reimbursements in 2019.
Option One: allows providers to submit “some data” for MIPS after Jan. 1, thereby avoiding a negative payment adjustment in 2019. No incentive is earned for this option. Ex: one quality measure or one improvement activity for any point in 2017.
Option Two: allows providers to participate in the program for part of the calendar year. Providers can submit performance measure and improvement activity data across all required MIPS performance categories for a 90 day period while still qualifying for a “small” positive payment adjustment. Download our pathway to meeting MIPS/MACRA for suggested measures on page two.
For options one and two, you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you’ll need to send in your performance data by March 31, 2018.
Option Three: allows providers to evolve existing quality programs by enabling full participation. Providers submit data across all MIPS performance categories for the full calendar year and qualify for a “modest” positive payment adjustment. Refer to Medaxion’s suggested measures here.
Option Four: allows providers to join Advanced Alternative Payment Models in 2017. If providers sufficiently participate in Advanced APMs, they qualify for a 5% incentive payment in 2019 and are exempt from MIPS. For more information about Advanced APMs, refer to https://qpp.cms.gov/learn/apms.
Option Five: allows you to opt out completely. If you don’t send in any 2017 data, then you receive a negative 4% payment adjustment. We don’t recommend this.
Your practice can easily start with option one, two or four to become eligible this year. We have a team and process in place to help identify the best path forward. Click here, to schedule a free quality consultation.