September 09, 2016
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CMS: 'Pick your pace' for MACRA 2017 reporting

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CMS has released a list of data reporting options for the first year of the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act, allowing physicians to test the new initiative by submitting only some information, or submitting information for just part of the calendar year, in lieu of participating fully.

The announcement has been met with praise from the American College of Physicians and the American Academy of Family Physicians.

In a CMS Blog post, Acting CMS Commissioner Andy Slavitt said the new program allows physicians to set the pace of their participation for the first performance period, which begins on Jan. 1, 2017. During that year, eligible physicians and clinicians will be able to choose one of four options, ensuring they do not receive a negative payment adjustment in 2019.

“However you choose to participate in 2017, we will have resources available to assist you and walk you through what needs to be done … and your feedback will be invaluable to building this program for the long term to achieve outcomes that matter to your patients,” Slavitt wrote. “And however you choose to participate, your feedback will be invaluable to building this program for the long term to achieve outcomes that matter to you patients.”

Faced with the prospect of 10,000 new people entering the Medicare each day as baby boomers age, Congress in 2015 passed the Medicare Access and CHIP Reauthorization Act (MACRA) to increase the focus on patient outcomes and cut down on obstacles that make it harder for physicians to practice.

According to CMS, MACRA repeals the Sustainable Growth Rate formula and its annual payment cliffs, streamlines the current patchwork of reporting programs and provides payment incentives to physicians and clinicians who focus on quality patient care. These provisions are collectively referred to as the Quality Payment Program by CMS.

In advance of the Quality Payment Programs Jan. 1 debut, CMS released the following four data reporting options:

Test the program

Under this option, as long as physicians and clinicians submit some data to the Quality Payment Program, including data from after Jan. 1, 2017, they will avoid a negative payment adjustment. This option is designed to determine if a practice’s system is working, and that it is prepared for further participation in 2018 and 2019.

Participate for part of the year

Physicians and clinicians may choose to submit information for a reduced number of days, meaning a practice’s first performance period could begin later than Jan. 1 and still quality for a small positive payment adjustment. For example, if a physician submits information during part of the calendar year for quality measures, how their practice uses technology and what improvements they are undertaking, they could qualify for a small positive adjustment. A list of quality measures and practice improvements is available under the Quality Payment Program.

Full participation

This option is for practices that fully are prepared for the program on Jan. 1., and are ready to submit Quality Payment Program information for a full calendar year. Practices that report data on quality measures, technology use and improvement activities for the full year could qualify for a modest positive payment adjustment, according to CMS.

Advanced Alternative Payment Model

MACRA allows practices to participate in the Quality Payment Program through an Advanced Alternative Payment Model, such as Medicare Shared Service track 2 or 3, in 2017. Physicians and clinicians who receive enough Medicare payments, or see enough Medicare patients through the alternative model in 2017, would qualify for a 5% incentive payment in 2019.

According to CMS, the four options are based on feedback from thousands of physicians and other clinicians following its initial proposal in April. CMS plans to provide additional information on the options when it releases its final rule, which is expected by Nov. 1, according to Slavitt.

“We appreciate the sincere and constructive participation in the feedback process to date and look forward to advancing step-by-step in that same spirit,” Slavitt wrote. “We look forward to releasing the final details about the program this fall. Most importantly, we look forward to further engagement with physicians and other clinicians toward our shared goal of the highest quality of care and best outcomes for patients.”

In a statement, the American College of Physicians lauded the announcement, stating the changes allowing physicians multiple reporting options, without facing the risk of negative adjustments, was in line with recommendations it had made earlier this year.

“It is important to note that this announcement does not delay the initial performance period of MACRA; some level of participation would be required for each of the options in order for a practice to not be subjected to negative adjustments,” ACP President Nitin S. Samle, MD, MS, FACP, said in the statement. “However, it provides the time and flexibility needed for those practices to choose the pace of their participation, while allowing those who are ready to report beginning January 1, 2017 to be eligible for a positive payment adjustment. We look forward to working with CMS to ensure a smooth transition as implementation continues to move forward.”

 Robert Wergin, MD, chairman of the board of directors at the American Academy of Family Physicians, similarly endorsed the move, adding that their members had initial concerns about reporting requirements and the specter of negative adjustments.

“In our response to the proposed rules to implement MACRA, the American Academy of Family Physicians outlined a series of steps — including delay or flexibility in launching the performance year — that CMS could take to ensure the success of the payment reforms,” Wegin said in a statement released on the academy’s website. “Our recommendations were particularly important for physicians in solo and small practices. The options outlined by CMS Acting Administrator Andy Slavitt ensure that all physicians who participate in the program are not penalized in the first year.”

Additional reading:

https://blog.cms.gov/2016/09/08/QualityPaymentProgram-PickYourPace/

http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html