Take Action Now in the Quality Payment Program
Under the Medicare Access and CHIP Reauthorization Act (MACRA), clinicians are subject to Medicare payment adjustments based on information submitted to the Quality Payment Program (QPP). While the Centers for Medicare and Medicaid Services (CMS) deemed 2017 a “transition year” in the QPP and offers clinicians several options for reporting their 2017 data, eligible clinicians who do not participate will receive a negative payment penalty.
One of three reporting options under QPP’s “pick your pace” program for 2017 is to collect and report on 90 days of data, which places our focus squarely on October 2, 2017 as the deadline for many family physicians to start collecting data. Now is the time for all eligible clinicians to make decisions, including identifying what you will measure and how. CAFP is here to help.
Background on the QPP is available in many places, including CMS’s official QPP website, CAFP’s QPP Playbook and Primer for Small and Rural Practice Family Physicians and AAFP’s MACRA Ready website. After catching up on the basic structure of the QPP, take the following steps to prepare:
Determine your eligibility for MIPS
Most California family physicians who accept Medicare patients are in the Merit-based Incentive Payment System (MIPS) track of the QPP. There are three primary exemptions from MIPS:
- “Low-Volume” clinicians who bill Medicare $30,000 or less in Part B-allowed charges a year OR provide care for 100 or fewer Medicare patients a year.
- Clinicians who are in their first year participating in Medicare.
- Advanced Alternative Payment Model (APM) Qualified Providers who participate in a: (1) Medicare Shared Savings Program (Track 2 and 3); (2) Next Generation Accountable Care Organization Model; (3) Comprehensive End Stage Renal Disease Care program – two-sided track; (4) Comprehensive Primary Care Plus program; (5) Oncology Care Model (two-sided risk); or (6) Comprehensive Care for Joint Replacement Payment Model (Track 1).
- Test the QPP: Submit data for one Quality measure, ,b>OR one Improvement Activity, ,b>OR the four required Advancing Care Information (ACI) measures and avoid a negative payment adjustment.
If you do not have an EHR or never reported to the Physician Quality Reporting System (PQRS) or the EHR Incentive Program (also called Meaningful Use), you might consider the “Test” option. You can still participate in QPP and avoid the payment penalty and this is a good introduction to quality reporting. For those clinicians without an EHR, you should focus on the Quality or Improvement Activity categories. Go to the QPP website’s list of 2017 Quality measures. Filter the list by “Data Submission Method” and select “Claims” from the drop-down list. Alternatively, refer to the list of QPP Improvement Activities.
- Partial Reporting: Submit at least 90 days of data for more than one quality measure, OR more than one improvement activity, OR more than the four required Advancing Care Information measures and avoid a negative payment adjustment. Clinicians who exercise this option may receive a small positive payment adjustment.
If you have participated in the PQRS or EHR Incentive programs and are comfortable with your EHR or qualified registry, “Partial” reporting is a great option. Say, for example, that you have been reporting the diabetes measures group under PQRS using a qualified registry. Leverage your experience in PQRS by reporting quality measures similar to those previously submitted. Measures groups are not available for reporting under MIPS, but the individual measures that were part of the diabetes measures group are available. Reporting these measures for patients seen throughout a continuous 90-day period will allow you to avoid the negative payment adjustment and possibly earn a small positive payment adjustment. This will also help you gauge your readiness for full reporting in 2018. Similarly, you can use your experience in the EHR Incentive Program and report on the ACI category.
- Full Reporting: Submit at least 90 days of data for all required quality measures, AND all required improvement activities, AND all four required Advancing Care Information measures to avoid a negative payment adjustment. Clinicians who exercise this option may receive a moderate positive payment adjustment.
To exercise the “Full” reporting option, clinicians must report at least six quality measures, complete up to four improvement activities (a combination of medium- and high-weighted activities) and report on required ACI measures to earn a base score, and include additional performance measures for a continuous 90-day period in 2017. “Full” reporting is a good option for those with several years of experience in the PQRS and the EHR Incentive Program and who are well-underway with QPP planning. By this point in 2017, clinicians interested in exercising this option likely should have measures selected and improvement activities underway.
- Determine the appropriate reporting option for 2017;
- Select measures and activities to satisfy the requirements of each performance category under MIPS;
- Design a quality-improvement strategy that satisfies the performance categories; and
- Optimize the use of health information technology (i.e., your Electronic Health Record (EHR)).
Confirm your MIPS eligibility today using CMS’s QPP website. You will see “check your participation status” on the right-hand side of the page, where you can type in your 10-digit National Provider Identifier. You can also contact Noridian Healthcare Solutions, the Medicare Administrative Contractor that processes Medicare Part B claims in California, at (855) 609-9960 or CMS at email@example.com or (866) 288-8292 with questions about your eligibility.
Pick your pace
By now the “Pick Your Pace” approach to reporting 2017 data may be familiar. There are essentially three reporting options available to clinicians in this first year of the QPP. While CAFP cannot tell you which option to select, as the optimal selection will depend on your practice, we offer the following thoughts on selecting a reporting option and measures within the three performance categories for 2017 (i.e., Quality, Improvement Activity and Advancing Care Information categories).
Access free technical assistance
CMS awarded $20 million to 11 organizations to provide clinicians in small, rural and Health Professional Shortage Area (HPSA) practices assistance with the QPP. CMS intends to invest an additional $80 million in this technical assistance program over the next four years. Health Services Advisory Group (HSAG) was awarded the contract in California. HSAG’s assistance is free and available immediately.
HSAG can help you:
HSAG will provide most assistance virtually, via telephone and email, but in some cases may also provide in-person assistance.
Enroll in HSAG’s free technical assistance program by calling (844) 472-4227 or visiting their online QPP Service Center. HSAG will return all emails and calls within 24 hours. CAFP encourages small and rural practice family physicians to visit HSAG’s service center, click “Register for Services,” and complete the brief form. HSAG will tailor its assistance to you based on the information you provide. The sooner you contact HSAG, the better! They anticipate an influx of registrations just prior to the October 2 deadline.
CAFP encourages every one of its members to check their eligibility for MIPS and, if they are eligible, to at least Test the QPP to avoid a negative adjustment. There is a great deal of assistance available to California family physicians: HSAG can help you to pick your reporting option and measures, and CMS has launched a helpline for clinicians with questions or concerns about the QPP. The helpline can be reached by calling (866) 288-8292 from 8 am to 8 pm Eastern Standard Time or emailing firstname.lastname@example.org. Finally, CAFP staff are always available to assist you. Contact CAFP’s Manager of Medical Practice Affairs, Sonia Kantak, at email@example.com or (415) 345-8667 with any questions.
About the Author
Leah Newkirk, JD, has significant experience developing organizational and educational programming on policy changes in health care, such as MACRA and the ACA. Much of her professional work has been dedicated to delivery system and payment reform and the adoption of health IT. Leah has a particular focus on designing and managing programs for individuals with chronic illness.
The articles provided in Practice Management News are general. They do not constitute legal, practice management or coding advice in any particular factual situation or create at attorney-client relationship. Consult your attorney or other professional for advice in your particular situation.