Anxiously awaiting CMS’ final rule detailing the Quality Payment Program (QPP)?
There’s still several weeks until the final rule is released—it’s expected by November 1, 2016—but CMS Acting Administrator Andy Slavitt recently offered a glimpse into what the first performance year will look like for eligible clinicians (ECs) under both the MIPS and APM tracks.
CMS received thousands of comments on the proposed rule, a provision of 2015’s MACRA legislation, most of which pinpointed physicians’ three main concerns:
- the program’s complexity
- the short timeframe for implementation
- the potential negative effects on solo, small, and rural practices.
Now, CMS has taken those comments into account and formulated a sort-of compromise that will allow ECs to avoid a negative payment adjustment in the program’s first payment year, 2019.
CMS had previously indicated its openness to alternative start dates beyond January 1, 2017. CMS has nixed that option, but instead will give ECs a choice of four participation options for the first performance year:
Option 1: Get Your Feet Wet
This option won’t earn you any incentive dollars, but it will let you avoid a negative payment adjustment in 2019. All you have to do is submit some data to the MIPS program for performance year 2017. How much data is “some” data? We don’t know yet—you’ll have to wait till the final rule is released. This 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,” Slavitt said in the September 8 announcement.
Option 2: Jump Right In
For ECs that plan to be fashionably late to the MIPS party—ready, just not ready on January 1—this option is for you. You can qualify for a small positive payment adjustment in 2019 by submitting MIPS data in all four categories for a reduced number of days in 2017. Again, we don’t yet know exactly what that reduced reporting period will entail.
Option 3: The High Dive
This isn’t really a new option—it’s simply a full year’s participation in MIPS, as the program originally intended. Practices that are ready to go on January 1 and report for the full performance year will qualify for a modest positive payment adjustment in 2019.
Remember, registries like AAO’s IRIS® and AOA MORE® can make MIPS participation nearly automatic, helping you report measures in three of the four MIPS categories: Quality, Advancing Care Information (ACI), and Clinical Practice Improvement Activities (CPIA). CMS pulls measures for the Cost category directly from your Medicare claims, resulting in no additional reporting requirements from you.
Option 4: Reverse Dive with a Somersault in the Pike Position
Also not a new option, but ECs can qualify for a full five percent incentive payment by ditching the MIPS track entirely in 2017 and instead participating in an Advanced Alternative Payment Model (APM). Unfortunately, ophthalmologists and optometrists likely won’t be able to participate in any of the six payment models that CMS has identified as advanced APMs:
- Comprehensive End Stage Renal Disease Care model
- Comprehensive Primary Care Plus model
- Medicare Shared Savings Program (MSSP) Track 2
- MSSP Track 3
- Next Generation ACO model
- Oncology Care Two-Sided Risk Arrangement model
When it comes to the APM track, it seems like eye care providers are on the outside looking in. But while there are currently no eye care-specific advanced APMs, all is not lost. Participation in a non-qualifying APM (like MSSP Track 1 or another ACO) will help you meet some of the MIPS requirements and could also give you favorable scoring.
It’s not the delayed start date that many physicians were hoping for, but this “pick your path” approach to QPP participation may ease physicians’ reporting burden, at least for the first year, while giving practices some extra time to ramp up to full participation.