Physicians should begin complying with new requirements for the Medicare Quality Payment Program (QPP) in 2017. Pay adjustments will go into effect in 2019 based on 2017 performance.
The QPP has two pathways: The Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). Cardiothoracic surgeons likely will follow the MIPS pathway for the foreseeable future, unless they participate in an Advanced APM through their hospital or another entity.
Consider Your Options Under the MIPS Track
Since the minimum reporting period for 2017 is 90 days, cardiothoracic surgeons have the flexibility to “wait and learn” about the program. Clinicians who are simply interested in avoiding a penalty in 2019 are required to do very little in 2017. Nevertheless, it is a good idea to participate in MIPS as fully as possible in 2017 since CMS is required, under law, to ramp up the program requirements and penalties in future years. CMS also is required to publicly report clinician performance data and has already started to do so on a limited set of data.
Here are some things you can do to get started with MIPS:
- Check that your electronic health record is certified by the Office of the National Coordinator for Health Information Technology. If it is, it should be ready to capture information for the MIPS Advancing Care Information category and certain measures for the Quality category.
- Consider using the STS National Database to extract and submit MIPS quality measure data to CMS. One benefit to signing up with a Qualified Clinical Data Registry is that quality data can be analyzed retrospectively and submitted to CMS at the end of the year versus having to submit claims-based data at the time a clinician submits billing claims to CMS. The measures offered in the STS National Database also are more relevant to cardiothoracic surgeons than what is offered through the traditional MIPS measure set.
- Identify appropriate Improvement Activities that your practice may consider undertaking for 2017 or future performance years.
- Monitor your performance by accessing feedback reports distributed by CMS. These include the 2015 Quality and Resource Use Reports (QRURs), which illustrate how your group practice performed in 2015 on the quality and cost measures used to calculate the 2017 Value Modifier, as well as the 2015 PQRS Feedback Report. These reports can help you better understand your reporting patterns, what is contributing to your overall performance, and how to identify opportunities for improvement. 2016 QRURs will be available in fall 2017.
- Use the CMS QPP website and additional resources listed below to see which measures and activities best fit your practice.
Consider Your Options Under the APM Track
Once familiar with the requirements for this track, you might want to consider taking the following steps:
- Research and understand your local payment and delivery landscape. Meet with leaders in your own system to understand their strategies and learn more about their goals.
- Confirm whether you are already a participant in any Advanced APMs for 2017. If you are, it is also important to:
- Verify with the APM administrator that you are included on the APM Participation List or Affiliated Practitioner List that they submit to CMS.
- Evaluate to what extent your Medicare and private payer revenues and the proportion of your patients are associated with these models, since this will determine whether you are a Qualifying Participant and eligible for an incentive under this track.
- Talk with the APM administrator to better understand the entity’s plan for distribution of the Advanced APM incentive payment if the APM qualifies for it in the future. Since the APM administrator would receive the incentive payment directly and be responsible for distributing it to APM participants, it’s important that you have a voice in this process.
- If you do not already participate in one of these models, identify potential partners outside of your immediate practice to advance coordinated care plans and innovative payment models.
- Think strategically about new resources your program may require to close key gaps in care. Present these to your system leaders or partners to encourage their investment in your growth.
- Continue to invest in certified electronic health record technology to communicate clinical care information and engage in quality measurement, as these are foundational requirements of Advanced APMs.
- The CMS QPP website includes search tools to help clinicians identify relevant measures in each of the MIPS categories. It also includes educational information, such as videos, fact sheets, and guidance documents on more specific aspects of both MIPS and APMs.
- MACRA Timeline from CMS
- STS Comment Letters to CMS on MACRA Implementation
Last updated: 5/16/2017