In a surprising blog announcement on Sept. 8, acting CMS Administrator Andy Slavitt announced that the Quality Payment Program (QPP) would allow several options for physicians to “pick their pace” of participation for the first performance period that begins Jan. 1, 2017.
These options include
- participation in an alternative payment model,
- incentives for completing partial and full year reporting, and most significantly,
- allowance for providers who “submit some data” to avoid a negative Medicare payment adjustment in the first payment cycle of the program (2019).
Insights from HIMSS: It is relatively unprecedented that CMS would release this much information in blog form before publication of a final rule. With the program’s go-live merely three months away, it was helpful to have general guidance from CMS prior to publication of the final rule. HIMSS has emphasized that physician implementation timelines are incredibly tight, and this guidance will assist eligible professionals with their intended path for the QPP. Regulatory requirements are complex and require time and attention to the details to fully understand the expectations.
Benefits of flexible reporting timelines: I think CMS has heard significant concerns about the timing and readiness for the reporting and performance requirements from providers, vendors and Capitol Hill. This nuanced approach and flexibility in reporting timelines will be welcomed by providers in the midst of an implementation or platform update, and those early in the EHR lifecycle who are still struggling to learn how to use their health data to change behaviors and improve outcomes.
The challenge for regulators will be the need for the Quality Payment Program to be budget-neutral. The Medicare Access & CHIP Reauthorization Act was authored in part to improve care quality and to eliminate the Sustainable Growth Rate and reduce Medicare spending. CMS must expect a significant number of physicians will not participate at a minimum level. Those physicians would then receive a 4 percent cut in their Medicare reimbursement.
The focus on improving care quality: I hope the QPP focus shifts away from avoiding penalties to improving care quality. The QPP has an opportunity to change the paradigm of quality improvement from a culture focused on meeting compliance baselines to a culture focused on learning which interventions truly improve the outcomes and quality of life for patients. As I travel across North America visiting ambulatory providers for the HIMSS Davies Award program, I am staggered at how often increasing adherence to standardized best practice is viewed a “quality outcome.” When asked how that improved adherence to best practice has improved the quality of life and health of the patient, many struggle to answer the question.
There is so much focus on current CMS quality reporting metrics (most of which are process improvement-focused measures) that outcomes seemingly become an afterthought. Providers are trying to improve care. However, many don’t have a framework for how to measure, monitor, and improve outcomes.
The QPP could provide that framework as long as the regulatory framework:
- focuses on using clinical quality measures that enhance care delivery, and ultimately,
- improves patient care outcomes…
…while not overly burdening the collection, analysis, reporting and leverage for change management.
Are you looking for best practices on how to meet the Quality Payment Program performance metrics? HIMSS has peer reviewed, evidence-based case studies on improving risk adjustment and empanelment, chronic disease management, reducing hospitalizations, and increasing patient access from the HIMSS Davies Award Program. Learn more about the Davies Award at www.himss.org/davies .