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Practices Can Choose Their Level of Participation in the Quality Payment Program

November 28, 2016:

In its final rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA), released October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) offers physician practices four options for participating in the first year of the Quality Payment Program implementation, beginning January 2017. The two tracks are alternative payment models (APMs) or the three levels of participation in the Merit-based Incentive Payment System (MIPS). These two options seek to take into account the broad diversity in the make-ups and capabilities of practices. This flexibility was designed to help ease practices into the Quality Payment Program by allowing them to “pick their own pace,” according to Andy Slavitt, acting administrator of CMS.

There was talk earlier this year of delaying the implementation of this pay-for-quality initiative by six months or more. Physicians, especially those in small, rural practices, had expressed concern that they would not be ready to comply with new requirements by this January. Instead of a delay, however, CMS is allowing physicians to choose their level of participation to help ensure that they do not receive a negative payment adjustment in 2019.

Providers (physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists) are eligible to participate in the QPP by selecting one of two participation paths: APM or the fee-for-service-based MIPS. For those opting for the former, providers can join any of a number of advanced APMs, such as the Medicare Shared Savings Program or the Comprehensive End-Stage Renal Disease Care Model. This option carries with it the greatest potential reward—a 5 percent incentive payment in 2019, as long as the practice sees at least 20 percent of its Medicare patients through the APM.

To participate in MIPs, a clinician must bill more than $30,000 per year to Medicare and serve more than 100 Medicare patients annually. Providers choosing the MIPS option may be eligible for a performance-based incentive payment adjustment in 2019 depending on the level of participation selected. Three levels of participation are available, depending on the provider’s readiness:

Option 1: Test the Quality Payment Program

This is the toe-in-the-water choice: to avoid the negative payment adjustment down the road, all providers must do is submit some data to the QPP beginning in January 2017. CMS gives an example of “some data” as one quality measure, one improvement activity, or one Advancing Care Information measure for any point. This choice enables providers to make sure their systems are working and that they will be prepared for fuller participation beginning in 2018. Participation in this option avoids a negative payment adjustment.

Option 2: Participate for Just Part of the Year

For practices feeling a bit more confident, this is the swim-in-the-shallow-end choice. Providers may opt to submit information during a 90-day performance period beginning later than January 1, 2017, and still receive a small positive or neutral payment adjustment in 2019. Practices can choose from a list of quality measures and improvement activities to report.

Option 3: Participate for All of 2017

Some practices are ready for the deep end—this option is for them. The first performance period would begin January 1, and those practices submitting quality measures, data on how they use technology, and information on improvement activities can qualify for a modest payment increase in 2019. The amount will depend on how much data providers submit and performance results.

By 2022, those participating in QPP could receive as much as a 10 percent payment increase based on their data and performance.

For more information, the provider site for the QPP is at https://qpp.cms.gov/.


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