As many of you know by now, the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 contained the building blocks for an entirely new architecture in quality reporting. Beginning next year, it will do away with the current incentive programs, and instead install a unified framework of requirements for providers to follow—collectively known as the Quality Payment Program (QPP). As you’ll recall, the QPP is essentially a two-headed monster, allowing providers to participate in either the Medicare Incentive Payment System (MIPS) or alternative payment models (APMs), or both. The government estimates that 90% of providers will participate via MIPS in the initial years of the QPP.
Because the changes envisioned in MACRA were so monumental, with so little time to prepare, CMS considered delaying the implementation of its provisions, as we informed you in a July 13 alert. We are now able to significantly update that information.
Late yesterday, CMS acting administrator Andy Slavitt posted a message to his blog proposing 4 options to make MACRA participation more palatable for 2017. While these proposals do not include a delay in the start date of the new program, they do provide an easy way to avoid any reduction in Medicare reimbursement via 2019 penalties. This is the government’s way of allowing providers to “ease in” to the new quality program, to take it out for a test drive, without risking any bumps in the road—at least in the first year. Here are the options envisioned by Slavitt for 2017, each of which automatically protects you from the 2019 penalties:
- OPTION 1. Report “some” quality and cost data in 2017. While “some” is currently undefined, Slavitt stated this option “is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.”
- OPTION 2. Submit quality and cost data for only a portion of 2017. In addition to avoiding the penalty, providers could qualify for a small bonus in 2019 under this option.
- OPTION 3. Submit performance data for the entire calendar year in 2017. This option would also allow for the potential of a modest bonus in 2019.
- OPTION 4. Join an “advanced” APM. Acting administrator Slavitt writes:
If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.
An example of an advanced APM is the Medicare Shared Savings Program, Track 2 or 3.
The acting administrator for CMS went on to indicate that the final regulations for MACRA, expected later this fall, will provide further details of this “pick your pace” plan. Medac will provide you the full scope of those regulations as soon as they are released and reviewed.
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The information presented herein reflects general information that is current as of the date it was first published. In light of changes that may occur in the health care regulatory and compliance environments, the author’s presentation of this information might become outdated. Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.