Archived Publications eBook: MACRA is Reinventing the Structure of the P | Página 6

Under the Microscope
OPTIONS FOR 2017 PARTICIPATION
Recognizing that physicians are in various stages of readiness
for the new reporting system, CMS has outlined several
options for reporting during the first year of the program.
The options are:
1. Don’t Participate. If you don’t submit any 2017 data
then you will receive a negative 4% Medicare payment
adjustment in 2019.
2. Submit Something. With this option, as long as you
submit some data to the Quality Payment Program
you will avoid a negative payment adjustment.
3. Submit a Partial Year. If you submit 90 days of
2017 data, you may earn a neutral or positive
payment adjustment.
4. Submit a Full Year. If you submit a full year of 2017
data, you may earn a positive payment adjustment.
PREPARING YOUR PRACTICE FOR
VALUE-BASED CARE
We asked Lance Hebert, Vice President of Medical Group
Credentialing and Provider Enrollment at Echo if there
are things physicians should be doing to prepare for
implementation of the Quality Payment Program. First,
Hebert recommends that practices not delay. “With your
Medicare reimbursement at risk based on your participation
in the Quality Payment Program this year, it’s critical that
you start now. Don’t leave money on the table by failing to
prepare.” Hebert offered a few additional recommendations:
• Understand the requirements. CMS and a host of
others have offered numerous training materials to
help educate physicians about the new requirements.
Become familiar with the MIPS reporting requirements
and the Advanced APM concept.
• Choose your path. Decide if you will participate in
MIPS or an Advanced APM. While most clinicians will
initially participate in the Quality Payment Program
under MIPS, confirm whether you are a participant in
any of the risk-based models that are exempt from
MIPS reporting and automatically eligible for a 5%
payment incentive.
• Decide how you will participate. As summarized
above, CMS has outlined options for participation that
allow clinicians to choose the pace at which they will
participate in the first year of the program. Review
the options and decide which you will pursue.
• Dedicate resources and explore platform solutions.
Surround yourself with talented resources for
technology, clinical quality, and regulatory compliance.
Whether your own staff or contracted experts, you
need dedicated resources tasked with ensuring
compliance with the new reporting requirements.
Platform solutions can help you capture, analyze, and
submit the new reporting requirements. Further,
prioritize training initiatives that can help optimize
your results. Best bet—find a partner who can
help with both!
• Have a plan and mitigate risk. Create a detailed
roadmap for your team to follow and an action plan
for each reporting requirement. It is also important to
understand the potential pitfalls and to have a concrete
plan in place to mitigate those risks. The transition to
reporting under the Quality Payment Program is not a
once-and-done project. It will require a long-term
vision and flexibility along the way.
The Quality Payment Program will require physicians,
hospitals, healthcare organizations, and medical groups to
support the heavy burden of data collection and the
associated cost necessary to survive in the world of
Quality Payment Program reporting. Additionally, this new
payment system will most certainly accelerate the shift in
hospital-physician relationships. Some physicians, especially
solo practitioners and those in smaller groups, may find
the stability of hospital employment more appealing. And
given the significant incentives to participate in Advanced
APMs, there will likely be more pressure to participate in
risk-bearing relationships.
References:
Medicare Access and CHIP Reauthorization Act of 2015, https://www.congress.gov/bill/114th-congress/house-bill/2/text
Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule,
and Criteria for Physician-Focused Payment Models, a Final rule with Comment Period by the Centers for Medicare & Medicaid Services, May 9,
2016, https://www.gpo.gov/fdsys/pkg/FR-2016-11-04/pdf/2016-25240.pdf
Quality Payment Program Website, https://qpp.cms.gov/
Slavitt, CMS Blog on Quality Payment Program, (2016)
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Reprint from WINTER 2017 Provider Advisor