The Medicare Access and CHIP Reauthorization Act (MACRA) Quality Payment Program (QPP), consisting of the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs), was initially mandated to start January 1, 2017. Because MIPS is a very complex regulation with percentiles, weighted scoring and new technology requirements, the quickly approaching deadline caused recent concern and inhibitions from the healthcare community, despite CMS’ confidence in providers’ ability to successfully begin the program in 2017.
In response to this feedback, CMS has now introduced a Pick Your Pace initiative for 2017 QPP participants.1 The full and final details will be released along with the MACRA final rule in November, but the basics of the initiative have been outlined in the CMS blog.
CMS will now allow QPP participants four options in 2017. Here are some of our insights on these initiatives:
1. Option 1: Test the QPP
a. CMS says: “As long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment”
b. What it means for you: As long as you send any data to CMS during 2017 — containing at least some part of 2017 data — you won’t face a penalty for payment. It also implies that such providers will not receive any positive adjustments. So effectively, it is a 0 percent incentive for such providers in 2017.
c. Payments: 0 percent adjustments to such providers. No negative payments.
2. Option 2: Participate for part of the calendar year
a. CMS says: “You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than January 1, 2017, and your practice could still qualify for a small positive payment adjustment.”
b. What it means for you: The “reduced number of days” may mean the return of the 90 day reporting period, although CMS will clarify further on the minimum acceptable duration in the final rule. The “small positive payment” implies providers may be given a positive adjustment, but it will be less than another provider with the same CPS, but who has report calendar year.
c. Payments: 0 percent or a small positive adjustment to such providers. No negative payments.
3. Option 3: Participate for the full calendar year
a. CMS says: “For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on January 1, 2017. For example, if you submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a modest positive payment adjustment.”
b. What it means for you: This is the standard MIPS track from the MACRA rule. Providers would be judged on their national percentile for their CPS and given a positive adjustment based on the benchmark. This also implies there are no negative adjustment options for MIPS in 2017. Under this option, providers could either have a positive adjustment or 0 percent adjustment. The negative adjustment will start in 2018 when option 3 will be the only option available.
c. Payments: 0 percent or positive adjustments to such providers. No negative payments.
4. Option 4: Participate in an APMs in 2017
a. CMS says: “Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.”
b. What it means for you: This is the standard APM track from the MACRA rule. Those who are participating in any APM will be judged based on the parameters of that APM. The risks and rewards are different across APMs, however, qualified participants (those who are in an advanced APM and meet MACRA thresholds for billing and volume) under the APM track will be exempted from MIPS and will get a 5 percent lump sum payment from CMS. This is the same APM track introduced in the proposed rule in May.
c. Payments: 5 percent lump sum to such providers. Risks depend on the APM program.
CMS has removed negative adjustments under MIPS for 2017 as long as providers submit a small amount of data for even just a single day. Positive adjustments still exist, and providers can attest for a shorter period of time and still receive some positive payment, whether this is 90 days or something further will be clarified in the final rule. The last two options are the standard MACRA payment programs introduced in the proposed rule. Here, providers attest for the full calendar year and are judged on their national percentile with one notable exception for MIPS participants: you won’t get a negative adjustment even if you fall below the 50th percentile in your CPS. Though this holds true only for 2017.