Does quality reporting have a way of making you feel like a clown at the rodeo? Help is on the way.
On October 14, 2016, CMS released the MACRA final rule that details the structure of the Quality Payment Program (QPP). Based on thousands of comments and conversations with over 100,000 stakeholders, CMS has made changes in the final rule that offer additional support and flexibility to participants.
Exactly what does the final rule entail?
We know ECPs love data and details, but let’s start by taking a step back and leaving the complexities of measures, reporting, and scoring behind. The most important question is ‘what does MACRA mean for eye care practices, long-term?’
Answer: The QPP is basically your kick in the pants to start moving from volume to value. Simply put, value means higher quality care (defined by CMS’s quality strategy) at a lower cost.
How that goal is accomplished will vary depending on your particular practice, its providers, and its patients. The QPP provides a framework for making changes, reporting your progress, and placing you on a continuum based on your performance.It’s going to either financially reward you or penalize you based on how well and how quickly you adapt as compared to the other participants.
Remember—the QPP is budget-neutral, so the “losers’” penalties finance the “winners’” incentives.
Here are the top takeaways from the final rule. This list assumes that you’re already familiar with the basics of how the QPP is supposed to work. If you’re not, look here.
What’s the same: The participants.
Participants in the QPP for performance years 2017 and 2018 include physicians, physician assistants, nurse practitioners, certified nurse specialists, and certified registered nurse anesthetists who treat a certain number of Medicare beneficiaries. They are collectively referred to as ECs (eligible clinicians).
What’s different: The threshold for participation.
You’re eligible QPP if you bill Medicare more than $30,000 per year or provide care to more than 100 Medicare patients per year. If 2017 is your first year participating in Medicare, you’re exempt from the QPP in 2017 and will instead begin in 2018. If you’re a solo practitioner planning on retiring prior to 2019, you’re also off the hook.
Run a pediatric practice and think you’re home free? Think again. Private payers have a history of taking Medicare’s lead. So even if you’re not subject to the QPP now, it pays—literally—to listen up.
What’s the same: The basic structure of the QPP.
There are still two tracks, MIPS and advanced APM. Most providers, especially many specialists like ophthalmologists and optometrists, will still participate in MIPS. The four MIPS scoring categories haven’t changed, and you can still choose whether ECs in your practice participate individually or as a group.
What’s different: Cost doesn’t count! (this year)
In the proposed rule, the Resource Use (aka cost) category was slated to make up 10 percent of ECs scores in performance year 2017, affecting your adjustment in payment year 2019. Now, the cost category will be calculated in 2017 for data-gathering, but it won’t be factored into your score until performance year 2018. That means that your Resource Use score will affect your payment adjustment in 2020, not 2019.
- Tip: Remember, CMS will pull cost data directly from your submitted claims, with no additional reporting needed from you.
And that 10 percent slice of your score? It’s been shifted to the Quality category (the category that replaces PQRS). Quality measures are now 60 percent of your 2017 score.
What’s the same: The program’s official start date is still January 1, 2017.
What’s different: There’s a “pick your pace” transition period.
If you are participating in MIPS, the final rule gives you some relief as far as your start date and reporting options. In fact, CMS Acting Administrator Andy Slavitt writes in his blog that “Other than a 0.5 percent fee schedule update in 2017 and 2018, there are very few changes when the program first begins in 2017.” The newly flexible MIPS participation options for 2017 are intended to give ECs the very best chance of avoiding a negative payment adjustment in 2019. Really, the only way to expose yourself to that potential 4 percent penalty is to completely ignore MIPS. For details on the 2017 participation options, check here.
January 1, 2017: For the best chance of a positive payment adjustment in 2019, start on this date.
October 2, 2017: If you plan to participate at all, this is the last date you can begin.
March 31, 2018: The latest date you can submit data for performance year 2017.