The final rule for the Quality Payment Program (QPP) authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was recently released. This rule has two tracks for Medicare providers to choose from: the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (APM). Fortunately, there are a lot of positives for community oncology practices in the final details. Additionally, there are now several options for providers to participate in 2017 at a pace that meets their readiness:
Participate fully in MIPS. Submit data for all required measures in all categories for the full year and be eligible for the maximum positive payment adjustment.
Participate partly in MIPS. Report a minimum of 90 days of data including one Quality measure, one Improvement Activity, or more than the required measures in the Advancing Care Information (ACI) performance category to avoid negative payment adjustment and be eligible for a modest positive payment adjustment.
Submit some data. Report on one measure in the Quality category, one Improvement Activity, or the required number of measures of ACI to avoid a negative MIPS payment adjustment.
- Participate in an Advanced APM and avoid MIPS participation.
Oncology practices participating in the Center for Medicare and Medicaid Innovation’s (CMMI) Oncology Care Model (OCM) also have some readiness choices. These practices now have the option to participate as Advanced APMs in 2017. An Advanced APM is a two-sided risk model that totally exempts practices from MIPS participation. Those considering this option need to look carefully at the pros and cons of moving more quickly to a two-sided risk model versus participation in MIPS. The upside of the two-sided risk option is that practices are eligible for an additional 5% bonus payment from CMS, but they must achieve cost savings and improve patient outcomes, or they will face a penalty.
Practices that do not participate at all in 2017 will receive a 4% negative payment adjustment in 2019.
Start Preparing for MIPS Today
Now that the final MIPS rule has been issued, there are various activities practices can undertake to ensure they are well positioned to succeed when the program launches in January. The following are several critical areas all oncology practices should consider.Engage your electronic health record (EHR) vendor about readiness for MIPS.
Understanding the practice’s electronic health record (EHR) MIPS capabilities and knowing when program reporting functionality will be available are critical first steps, as they enable the practice to determine which participation option is best for them. Requirements for the different levels of participation for 2017 must be closely examined and compared with practice readiness, both from technology and process standpoints. Once the level of readiness has been determined, providers can then decide if they are capable of submitting a full year of data, which would allow the opportunity for the maximum incentive payment in 2019.
If neither the practice nor its technology is fully prepared to begin reporting on January 1, an action plan can be created to identify areas in need of improvement and plan corrections during the first part of the year. Practices have until October 2, 2017 to start collecting performance data and still avoid a penalty. However, the more they report, the more opportunity there is for a higher incentive payment in 2019.
Examine practice performance in the Physician Quality Reporting System (PQRS)
Many oncology practices are participating in PQRS, a quality improvement incentive program providing rewards or penalties for reporting data to CMS. Those that are doing well in the program are in a good position to transition to MIPS because many of the quality reporting measures for MIPS are a continuation of PQRS, now called the Quality Performance Category.