In a blog post on Thursday, September 8, 2016, Centers for Medicare & Medicaid Services (CMS) Acting Administrator Andy Slavitt announced his agency’s intention to change the reporting timeline for the first year of the Quality Payment Program (QPP) in 2017. Recognizing the comments that CMS received from stakeholders on the timing of the first performance year, Mr. Slavitt wrote that his agency wanted to present eligible clinicians with multiple options for QPP participation and allow them to “pick their pace of participation for the first performance period that begins January 1, 2017.”
Choosing one of the options that CMS outlined (and will further detail in the QPP Final Rule, which is set to be released by November 1, 2016) ensures that clinicians do not receive a negative payment adjustment in 2019. The options include:
First Option: Test the Quality Payment Program
Clinicians must submit some QPP data, including data from after January 1, 2017, to avoid a negative payment adjustment. This first option is designed to ensure that their systems are working and that they are prepared for broader participation in 2018 and 2019. The assumption under this option (although not explicit) in the information announced thus far, is that clinicians choosing this track would not be eligible for positive payment adjustments in 2019.
Second Option: Participate for part of the calendar year
Clinicians can choose to submit QPP information for a reduced number of days in 2017, which allows their first performance period to begin after January 1, 2017. Under this option, clinicians could still qualify for a small positive payment adjustment in 2019.
Third Option: Participate for the full calendar year.
Clinicians that are ready to move forward on January 1, 2017, can choose to submit QPP information for a full calendar year, and their first performance period would begin on January 1. This option would allow these clinicians to qualify for a modest positive payment adjustment.
Fourth Option: Participate in an Advanced Alternative Payment Model (APM) in 2017
Clinicians that are prepared can choose to participate in the QPP by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Program Accountable Care Organization Track 2 or 3 in 2017. If the clinicians choosing this option meet the established QPP thresholds, they would qualify for a 5 percent incentive payment in 2019.
It is important to note, that HIMSS was one of the stakeholder organizations that asked CMS to change the QPP performance period from a full year in 2017 to a shorter timeframe. With the short timeline from the release of the final rule to January 1, 2017, HIMSS recommended that CMS change the reporting period for the Advancing Care Information Performance Category of the Merit-Based Incentive Payment System to 90 days. Additionally, for those clinicians pursuing the APM Track, HIMSS proposed that they only be required to report for 90 days, with the threshold requirements prorated accordingly for a clinicians’ aggregate Medicare Part B payments for covered professional services and the number of patients who received covered professional services through the Advanced APM.
In addition, HIMSS asked CMS to redouble its efforts to educate the clinician community on the new Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requirements and ensure that the burden placed on individual and small practices is not too pronounced. This effort will become even more critical as the community approaches 2017 and the start of the first performance period.