You’ll find relaxed reporting requirements for year one of the federal Quality Payment Program (QPP) as CMS appears to be taking a toned-down approach to kick off its new era of quality reporting.
The QPP, which begins Jan. 1, 2017, with what CMS is terming a “transition year,” includes the merit-based incentive payment system (MIPS) and the much smaller advanced alternative payment model (APM) program.
Under MIPS, cost will not be an object – and, as previously hinted, you can do even a small part of the required reporting and still avoid a pay cut, according to the
QPP final rule released today.
The rule replaces the proposed rule released on April 27. This is a final rule with comments, which are due by 60 days after publication at the Federal Register, which is expected next week.
Note relaxed thresholds to avoid negative payments
You’ll find 2017 to be a transition year for MIPS, for which CMS is establishing “special policies” – which may extend into 2018.
“We envision that it will take a few years to reach a steady state in the program and we therefore anticipate a ramp-up process and gradual transition with less financial risk for clinicians in at least the first two years,” states CMS.
In 2017 CMS will “allow physicians to pick their pace of participation,” as presaged in Acting CMS Head Andy Slavitt’s blog post of Sept. 8 (
PBN 10/3/16).
If you do no reporting in 2017, you will get a 4% cut. If you report some data, but not 90 to 365 days’ worth of full reporting data, you get no payment adjustment. If you report full MIPS data for 90 days, you will get some upward payment adjustment depending on performance.
If you successfully do full, year-long reporting, you will receive up to a 4% pay hike, with “exceptional performers” who achieve a final score of 70 or higher eligible for “additional positive adjustment for each year of the first [six] years of the program” out of CMS’ bonus pool of $500 million.
You can report just one quality measure, one improvement activity or the required measures in the advancing care information category to avoid a negative adjustment in 2019.
“These transition year policies for CY 2017 will encourage participation by clinicians and will provide a ramp up period for clinicians to prepare for higher performance thresholds in the second year of the program,” states CMS in an executive summary released along with the final rule.
Participants in advanced APMs — a small group including Shared Savings Program tracks 2 and 3; Next Generation ACOs; Comprehensive ESRD Care (large dialysis organization arrangement); and the Comprehensive Primary Care Plus (CPC+) program – can qualify for up to a 5% positive payment adjustment without MIPS reporting.
New MIPS formula removes cost, revises other elements
The MIPS program replaces a number of current reporting programs across four sections – quality, which corresponds to the physician quality reporting system (PQRS); resource use, or cost, replacing the value modifier (VM); advancing care information, replacing meaningful use; and a new category, clinical practice improvement activities.
Your quality score will comprise 60% of your total MIPS score, up from the proposed rule’s 50%, according to the final rule. The cost component – to be computed by CMS based on provider billings without separate provider reporting – will be worth 0% of your score in 2017, instead of 10% as proposed. Yet CMS notes that the cost score will come into play in coming years.
"Each medical practice needs to assess where they are," advises Robert Ramsey, a health attorney with Buchanan, Ingersoll and Rooney in Pittsburgh, Pa., noting that many "small groups may not be ready at this point." But the lax transition-year reporting "at least protects them from any downside risk," adds Ramsey, provided a practice meets the minimum requirements.
Clinical improvement activities will be worth 20%, and advancing care Information worth 30%, rather than 15% and 25%, respectively, as proposed.
CMS also proposes to raise the minimum billing limit for MIPS participation to $300,000 from the proposed $100,000 – which, along with the 100-Medicare-patient lower limit, CMS say will exclude “32.5% of all clinicians billing Medicare Part B services or over 380,000 clinicians” – and suggested that it would expand the list of entities eligible for the advanced APM program by including a new “Other Payer Advanced APMs” category.
CMS “solicited and reviewed over 4,000 comments and had over 100,000 physicians and other stakeholders attend our outreach sessions” before publishing the final rule, it says. Access the full 2,300-page rule and executive summary
here.