The start date for the first performance period under MACRA hasn’t changed, but CMS released a statement Thursday about flexible reporting options for the first year that should help reduce physician fears.
Andy Slavitt, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS), says CMS plans to give physicians multiple options for participating in the Medicare Access and CHIP Reauthorization Act (MACRA) for the first performance period that begins January 1, 2017. The plan effectively allows physicians to pick their pace of participation in 2017, including partial-year reporting options to ease the transition into MACRA.
“Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019,” said Slavitt.
The final rule, released by November 1 of this year, will provide full details. In the meantime, to help you understand what these choices might mean for you, we’ve provided a synopsis of the options, as provided by Slavitt, as well as our perspectives of each.
Option 1: Test the Quality Payment Program
By submitting some data, including data from after January 1, 2017, to the Quality Payment Program (QPP), the new value-based reimbursement system, physicians will avoid a negative payment adjustment. This will allow physicians time to learn more about MACRA and test the systems and processes they’ve put in place before moving into broader participation in 2018 and 2019.
Option 2: Participate for Part of the Calendar Year
With this option, physicians can choose to report information for a reduced number of days. Their performance period could begin later than January 1, 2017, and their practice could still qualify for a small positive payment adjustment.
CMS gave the example of submitting information for part of the year “for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking.” We take that to mean there will be reporting requirements for each of those categories associated with this option when the final rule is announced. Additionally, we won’t know until the final ruling, but it is possible that CMS will specify certain dates physicians can start reporting during the year, rather than allow for random start dates.
Option 3: Participate for the Full Calendar Year
Practices prepared to start reporting on January 1, 2017, can choose to report their data through the QPP for the full calendar year. Their first performance period will begin on January 1 and apply through December 31, 2017.
Physicians who choose this option will submit information on quality measures, technology use, and clinical practice improvement activities for the entire year, qualifying them for a modest positive payment adjustment.
Slavitt noted CMS has already seen physician practices of all sizes successfully submit a full year’s worth of quality data and that many practices will be ready to do the same on January 1.
Option 4: Participate in an Advanced Alternative Payment Model in 2017
The fourth option allows physicians to participate in the QPP by joining an Advanced Alternative Payment Model (APM) rather than reporting quality data to the QPP via the Merit-Based Incentive Payment System (MIPS). Physicians who choose this option and see enough of their Medicare patients or receive enough of their Medicare payments through the Advanced APM in 2017 would qualify for a 5 percent incentive payment in 2019.
Although it was not said outright in the statement, we believe it is implied that choosing to report nothing in 2017 means you are still subject to a maximum penalty of up to -4%.
Overall, we believe, and the language used appears to imply, that some reporting in the Quality, Clinical Practice Improvement Activities, and Advancing Care Information categories of MIPS will be expected for each of the first three options.
Regarding option 1, we hope you don’t have to leave money on the table. But if you really do feel completely unprepared (there’s still time to change that) and choose to participate in option 1, we encourage you to make the most of the time by truly committing to developing or outsourcing Chronic Care Management and care coordination services, and putting your systems and processes in place as early as possible. Really learn what works and what doesn’t. And make sure 2019 is the only year of positive payment adjustments that you miss out on.
Regarding option 2, we would encourage you to take action now so you can fully participate rather than minimally participate. What if delaying by a few months makes it tougher to get started or gives a competitor an advantage? What if the financial bump is critical to your practice surviving or you remaining independent? And why get behind the curve on how you’re paid compared to other physicians?
Regarding option 3, if you are prepared or could be prepared by January 1, why delay participating fully? Potentially qualifying for a positive payment adjustment has obvious advantages. But as a bonus, you could be one of the physicians who helps set the bar for value-based care and ultimately raises the standard in the industry.
Regarding option 4, the choice to report through MIPS or join an Advanced APM has been on the table since the proposed implementation plan was announced in April. An Advanced APM wasn’t on the radar for most physicians anyway, and this announcement is unlikely to change that. It is still estimated that 90% of physicians will participate in the QPP by reporting through MIPS, largely because qualifying APMs require a large amount of risk and there are strict requirements associated with being an advanced APM.