Physician Practice

CMS provides increased flexibility for practitioners under Quality Payment Program

Physician Practice Insider, November 1, 2016

On October 14, CMS issued a final rule with comment period implementing the Quality Payment Program (QPP), which is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The Quality Payment Program replaces several individual programs applicable to clinicians including the Sustainable Growth Rate (SGR) update factor to the Medicare Physician Fee Schedule (MPFS), the Physician Quality Reporting Program (PQRS), the Physician Value-based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) incentive program for clinicians.

With the exception of the SGR, various components of these different programs are subsumed into a single QPP. The QPP will reform Medicare payments for more than 600,000 clinicians across the country, and the QPP provides two tracks or pathways for clinicians to participate and avail themselves of potential bonus payments:

  • Advanced Alternative Payment Models (APM), and
  • Merit-based Incentive Payment System (MIPS)

Key provisions of the final rule include that 2017 and 2018 are transition years for performance, and 2019 and 2020 will be transition years for payment impact. Details regarding transition policies for 2018 will be published later in 2017.

Eligible clinicians (EC) include physicians, nurse practitioners, physician assistants, clinical nurse specialists and certified registered nurse anesthetists for 2017. (Other clinicians will be added in 2019.) ECs can choose from the two tracks based on their practice size, specialty, location, and patient population. The first performance year is 2017 and the first payment impact year is 2019. To avoid the negative 4% payment impact in 2019, ECs have to make decisions regarding which track they choose to participate by January 2017. The negative payment impact increases in subsequent years of the program from 4% in 2019 to 9% by 2022. If ECs participate in MIPS, CMS provides additional options including reporting for a 90-day continuous period in 2017 and reporting less than the full set of measures. CMS estimates about half of ECs will participate through MIPS. In addition, EC performance under MIPS or their participation in an Advanced APM can affect the financial benefit clinicians can qualify for in 2019. For the first performance year, data is required to be submitted to CMS by March 31, 2018.

Clinicians that newly enroll in Medicare in 2017 are exempt from the QPP for their first year. In addition, the final rule expands the low Medicare patient volume exception for clinicians by making the thresholds higher—$30,000 in Medicare charges and less than or equal to 100 Medicare patients. CMS estimates that this will result in 32.5% of ECs in solo or small practices being excluded, meaning they will have no negative impact to their payments in 2019 if they choose not to participate in 2017. If they do participate, they still can qualify for financial benefits.

This article originally appeared on Medicare Compliance Watch. Click here to read the full article.

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