‘Pick Your Pace’ of Adoption of the Quality Payment Program

The Centers for Medicare and Medicaid Services (CMS) is offering physicians four options for how they implement the Quality Payment Program, which begins Jan. 1, 2017. Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019.

First, a little background. In 2015, Congress passed the Medicare Access and CHIP Reauthorization Act, called MACRA. This massive piece of legislation repealed the Sustainable Growth Rate (remember those yearly SGR ‘cliffs’ for Medicare reimbursement that Congress considered?); and streamlined the patchwork of Medicare reporting programs. At its core, MACRA offers opportunities for clinicians to earn more by focusing on quality patient care as well as incurring payment penalties if you do not reach the necessary quality benchmarks. This portion of MACRA is called the Quality Payment Program or QPP.

CMS is expected to release the final rule outlining all the details in November.

The recent announcement about the four options gives you a little breathing room to ease into the new Quality Payment Program. Briefly, here are your options:

First Option: Test the Quality Payment Program

With this option, as long as you submit some data to the Quality Payment Program, including data from after Jan. 1, 2017, you will avoid a negative payment adjustment. This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.

Second Option: Participate for part of the calendar year

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 Jan. 1, 2017 and your practice could still qualify for a small positive payment adjustment. For example, if you submit information for part of the calendar year for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a small positive payment adjustment. You could select from the list of quality measures and improvement activities available under the Quality Payment Program.

Third Option: Participate for the full calendar year

For practices that are ready to go on Jan. 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 Jan. 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. We’ve seen physician practices of all sizes successfully submit a full year’s quality data, and expect many will be ready to do so.

Fourth Option: Participate in an Advanced Alternative Payment Model in 2017

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.

Learn more on the CMS Blog here.

The NCMS is gearing up to offer you educational programming to help you understand and make the transition to this new program. We have already been offering free workshops through our partner organization, the National Rural Accountable Care Consortium (NRACC) to help practices not affiliated with an Accountable Care Organization learn about how to succeed in this new quality driven payment environment. Learn more about the workshops and how you can participate by reading the article in this issue of the Bulletin titled ‘Don’t Miss FREE October Practice Transformation Workshops.’

Be sure to watch the Bulletin for updates on other educational programming and launch of our online survival kit.

 
 

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