The Medicare incentive programs with which you and your medical practice are familiar will soon be no more. As of January 1, 2017, these programs (including the Electronic Health Records (EHR) Meaningful Use Incentive Program, the Physician Quality Reporting System (PQRS), and the Physician Value-Based Modifier Program) will morph into the new Medicare Quality Payment Program (QPP). The QPP will also include a fourth category of incentives entitled “Clinical Practice Improvement Activities”, which we discuss in more detail below.
The purpose of the QPP is to create one central program that will govern Medicare Part B payments to physicians, while incentivizing physicians to increase quality of care and decrease inefficiencies in the cost of care for Medicare patients. Participation in the QPP will be mandatory beginning January 1, 2017. The QPP will either reward or penalize physicians and their practices by adjusting their reimbursement rates under the Medicare Physician Fee Schedule two (2) years after the reporting year. Therefore, physicians/practices will have their reimbursement rates adjusted in 2019 based on their reporting data for the year 2017.
As we noted in our first blog post in the Series, accessible here, physicians will have the option to choose between two payment tracks under the QPP: (1) the Merit-Based Incentive Payment System (MIPS); and (2) an Advanced Alternative Payment Model (Advanced APM). This blog post will discuss the basics of the MIPS and how to qualify for the MIPS in 2017, while our next post will touch on the basics of participation in Advanced APMs.
Basics of the MIPS
Each physician or group practice (you may report individually or as a group) participating in the MIPS in 2017 will earn a “composite performance score” based on the physician/group’s scores within the following four (4) categories:
- Quality of Care – 60%
- Explanation: Scored based on the reporting of “quality measures”, which will be published annually by CMS. Physicians will be able to choose which quality measures they will report each year.
- Replaces: PQRS and quality component of the Value-Based Modifier.
- Advancing Care Information – 25%
- Explanation: Scored based on the reporting of EHR use-related measures with which you are familiar from the current EHR Meaningful Use Incentive Program. However, unlike the existing program, the QPP measures will not have “all-or-nothing” targets.
- Replaces: EHR Meaningful Use Program.
- Clinical Practice Improvement Activities – 15%
- Explanation: Scored based on attestation by the physician/group that the physician/group has performed certain care coordination, beneficiary engagement, population management and patient safety activities.
- Replaces: New Program.
- Resource Use – 0%
- Explanation: Scored based on per capita patient costs and episode-based measures. CMS collects and analyzes the data from your claims submissions. No additional reporting will be required.
- Replaces: Cost component of the Value-Based Modifier.
How to Qualify for 2017
CMS has eased the reporting requirements for the first year of the QPP. No physician/group will be required to begin collecting data in accordance with the QPP’s requirements on January 1, 2017 (but may elect to do so). To receive a neutral or positive payment adjustment, physicians/groups will need to report data for only a 90-day performance period during the year. There are also minimum threshold reporting requirements to avoid a negative payment adjustment and full participation requirements which are more likely to result in a guaranteed positive adjustment. The table below organizes the requirements in an easy-to-read format:
Final Thoughts on Qualifying for the MIPS in 2017
- Get involved sooner rather than later. CMS has kept reporting requirements minimal in 2017 in order to encourage clinicians to participate in the QPP. Take advantage of that opportunity to ensure your practice has the right software to report the quality and EHR use-related measures. Since adjustments will be made based on threshold scores, it may be easier in 2017 to earn a positive adjustment, and even an exceptional bonus, than in later years.
- Ensure that your current EHR technology meets the requirements for the QPP in 2017, including reporting capabilities for quality measures and EHR use-related measures. The easiest way to do this is to contact your EHR vendor.
- CMS has given providers plenty of time to report 2017 data. The deadline for reporting 2017 data is March 31, 2018.
As always, if you have questions specific to your practice, please contact a knowledgeable and experienced attorney.