Medicare’s new Quality Payment Program remains a work in progress, but the Centers for Medicare and Medicaid Services (CMS) appears to be taking physicians’ suggestions for improvement to heart and the program that is taking shape seems to be one that will be less burdensome for doctors than the combined legacy Medicare reporting programs.
Missing from MACRA in 2017: 2 Meaningful Use millstones. As of Jan. 1, something was missing in physicians’ lives, but it wasn’t missed. After Dec. 31, 2016, clinical decision support and computerized physician order entry measures—carryovers from the Meaningful Use program--were eliminated from its QPP electronic health record (EHR) counterpart, the Advancing Care Information (ACI) category of the Merit-based Incentive Payment System (MIPS).
The AMA had advocated for this action, citing how those measures resulted in additional data entry and pop-up alerts that interfered with clinical workflow. Other improvements MIPS made to the legacy reporting programs included fewer required quality measures (six, as opposed to nine in the former Physician Quality Reporting System, or PQRS, program), and the omitting of cost measures (formerly the value-based modifier) from 2017 MIPS performance scores.
Education campaign helps physicians avoid penalty. CMS helped ease physicians into its new payment system with the “Pick Your Pace” options, including one that offered no cash bonus but allowed physicians to avoid a penalty for 2019. To promote awareness of this option, the AMA launched the “one patient, one measure, no penalty” campaign, which offers a step-by-step guide to completing the process.
“It’s a big challenge all the way across.” Regardless of size, specialty or level of preparedness, medical practices were concerned that the implementation of QPP would be burdensome and time consuming, according to a survey conducted by the AMA and the KPMG consulting firm. One positive sign revealed by the survey was that participation in PQRS or had attested to meeting Stage 2 Meaningful Use requirements was linked to QPP readiness.
Three things to like. Three things to fix. There was a lot to digest in the 1,058-page proposed rule for the 2018 QPP program. In its comments to CMS, the AMA said it liked:
- The proposed accommodations for small practices.
- Continued improvements in the MIPS components compared with burdensome legacy programs.
- Allowing more flexibility on certified EHRs.
- The addition of more Improvement Activity choices for MIPS participants.
The AMA also expressed concerns about:
- The slow development of Alternative Payment Models (APMs)
- A lack of flexibility on APM financial-risk standards.
- Confusion over the definition of a “small practice.”
Physicians put on alert. As the Oct. 2 deadline for physicians choosing the 90-day option out of the four “Pick Your Pace” categories, the AMA alerted physicians to:
- Get up to speed on performance categories; review the data in their CMS feedback reports.
- Make sure they had picked either the minimum, partial or full participation “pace” if choosing the Merit-based Incentive Payment System option instead of the APM route.
- Pick which quality, Advancing Care Information and Improvement Activities measures that best apply to their practice.
- And decide whether to report as an individual or group.
Positive outlook for 2018. The AMA issued a summary of the more than 1,600-page QPP 2018 final rule in which much more items were given a “thumbs up” evaluation than given a thumbs down. “A number of the policies that were proposed for the 2018 performance year and have now been finalized are based on our recommendations,” the summary states.
Positive actions the CMS took included:
- Raising the low-volume threshold for MIPS participation from 100 patients—or $30,000 in Medicare revenues annually—to 200 patients, or $90,000 in Medicare revenues.
- Postponing a mandate to upgrade to 2015-edition certified EHRs.
- Not increasing requirements for the number of quality measures.
- Adding an ACI hardship exemption for practices with 15 or fewer physicians.
- Adding a hardship exemption for physicians affected by hurricanes or wildfires.
CMS estimates that only 37 percent of clinicians who bill Medicare will be required to participate in MIPS next year.
