The end of the year is always hectic for oncology practices, but 2017 is proving exceptionally busy as CMS' Quality Payment Program (QPP) transitional year comes to a close. Many practices participating in the Merit-based Incentive Payment System (MIPS) are hyper-focused on their data collection and organization for performance year 2017. Although it is easy to focus on just the current year, oncology practices should not neglect the opportunity to plan for 2018. For all practices—regardless of the extent of their participation in MIPS—this is the time to get organized and develop an action plan so they can hit the ground running next year.
Although some practices may feel like they have time to get organized or are on the fence about participating in 2018, next year will be crucial to oncologists for several reasons. At AmerisourceBergen’s Quality Reporting Engagement Group (QREG), we estimate that the average 2019 financial costs for nonparticipation in 2017 will be approximately $8,283 per oncology physician, excluding Part B drug revenue, and $74,680 including Part B drug revenue. This is based on ION Solutions’ latest InfoDive benchmarks from August 2017 containing financial data for 450 physicians.
Based on how they perform, oncologists will receive either an upward or downward adjustment to their Medicare Part B payments. In other words, oncologists will pay either more or less, up to a certain percent. We know that these adjustments will continue to occur more often, affecting 4% of payments in 2019 and up to 9% in 2022. Oncologists could see a substantial cut or increase in Medicare payments, depending on their MIPS score.
Adjustments are felt 2 years after the performance year, so the actions a practice takes today will affect the future. Most important, the proposed rule in front of CMS that outlines amendments to the 2018 QPP indicates that the reimbursement adjustment could be applied to Part B drugs furnished by a MIPS-eligible clinician. We are all waiting to see how this is addressed in the MIPS final rule, due to be published in early November. With so much money in question over the long term, participating will ensure a practice’s financial viability going forward. Participation in MIPS also has an impact on a practice’s reputation. A major goal of the QPP is to foster patient engagement. Medicare will publish MIPS scores publicly on its Physician Compare website, encouraging patients to shop around and truly act as prudent consumers of healthcare. With a click of a button, a patient can see a physician’s entire MIPS score and compare that with the performance of all physicians, not just other oncologists.
Scores are determined by the amount of data that practices submit, whether it is simply test data (1 quality measure or 1 improvement activity for any point in the year), partial data (90 days’ worth), or full data (for the complete performance year). Because composite performance scores and adjustments are determined based on the amount of information submitted and the completeness of the data, we recommend that practices shoot for the stars and submit either 90 days’ or a full year’s worth of performance data from 2017. That would give CMS more information to weigh and ultimately give patients a more complete view of a practice.
Recently, our oncology practice clients have been asking us how to prepare for a complete submission in 2018, learn all the rules, and engage all staff. For other oncology practices with the same questions, I have some practical advice. To effectively participate in MIPS, by the end of this year, choose an internal champion—someone who can dedicate significant time and energy to organize and execute the practice’s effort over the next year. A small practice that cannot fully dedicate 1 person can assign a task force of 3 or 4 people to share the responsibilities. Either way, the goal between now and the end of this calendar year should be clear: Be able to articulate how the practice will report to MIPS in the year ahead.
So how do you get there? Allow the champion or task force an immersion period of 4 to 6 weeks to review the regulatory components and performance categories, study the 19 quality measures for oncology, and build an action-plan framework. The framework should lay out how the practice plans to report—will it be as a group or as individuals? From our experience, oncology practices may want to strongly consider reporting as a group. If providers decide to report individually, a practice may lose a level of control. On the other hand, unengaged members may drag the score down for an entire practice that reports as a group.