Responding to significant concerns about the impending start of the new reimbursement platform for Medicare as defined by the Medicare Access to Care and CHIP Reauthorization Act of 2015 (MACRA), the head of the Centers for Medicare & Medicaid Services (CMS) announced the creation of flexible options for 2017. On September 8, acting CMS administrator Andy Slavitt posted a blog that outlined the changes, stating the intention to “allow physicians to pick their pace of participation.”
The revelation was prompted by the outcry from physicians who reacted to April’s proposed rule outlining the implementation of MACRA. The new Quality Payment Program (QPP), set to stage the initial performance year in 2017, incorporates two pathways: physicians can either choose to participate as a qualifying member of an advanced Alternative Payment Model (APM), or report through the Merit-based Incentive Payment System (MIPS). Like the existing government incentive plans, to include the Physician Quality Reporting System, the QPP introduces increases for successful participants and reductions in reimbursement for those who are not.
The Advanced APM pathway remains available and was not impacted by the announcement. However, Slavitt’s blog revealed that CMS will exempt physicians from any risk of penalties for choosing one of three temporary reporting options for MIPS. The three options available in 2017 include:
- Full-year reporting, beginning January 1, 2017;
- Partial year reporting; or
- Test submission by reporting a minimal number of data elements.
In addition to avoiding penalties, the participation options may provide payment boosts. Opting for a full-year reporting equates to eligibility for a “modest” increase, while partial-year participants will qualify to receive a “small” positive adjustment. Those who choose the test submission option will have no upside, but will not be subject to penalties either.
You may be asking the natural question, “What are the parameters of these new options?” Unfortunately, Slavitt didn’t elaborate, saying instead that the “options and other supporting details will be described fully in the final rule.” These regulations and corresponding details are expected to be released to the public this fall.
In the interim, it is critical to note that MACRA, passed with bipartisan support, is the law. While the particulars of the implementation may have yet to be released, including the new options for 2017 and the remaining details about the program in general, we know that there are four pillars to the program that include: quality; resource use; meaningful use and clinical practice improvement. Under the law, these pillars are meant to further the existing programs and add a new one related to the reporting activities linked to clinical practice improvement.
Despite the flexibility in reporting for the upcoming year, it is not advised to let your foot off of the gas pedal. Practices should aim to continue their efforts in reporting these elements through the existing programs and make plans to continue to do so in the future.
Even with some flexibility in 2017, the ship has already sailed. The government is – and will continue to – gather data about your medical practice and administer financial consequences should the results not be within the parameters established for their expectations.