September 8, 2016: CMS Announces Flexibility with MACRA in 2017
As per the Proposed Rule for MACRA the Quality Payment Programs were scheduled to start on January 1, 2017 and would require participation for the entire calendar year. On September 8, 2016 CMS announced that eligible clinicians will have a variety of options for participation with the Quality Payment Program in 2017.
First Option: Quality Payment Program Testing
In order to avoid a negative payment adjustment, eligible clinicians will be able to submit "some" data to the Quality Payment Program in 2017. Specifically what data needs to be submitted has not been determined but details will be available no later than in the final rule on MACRA, scheduled to be released no later than November 1, 2016.
Second Option: Partial Year Participation
CMS will allow eligible clinicians to participate in the Quality Payment Program for part of the calendar year in 2017. Further details have not been provided, however, clinicians will likely be allowed to submit for six months or perhaps even shorter time frames. Again when additional information will be released on the exact requirements is not clear. CMS did share that participation in part of the calendar year could still result in upward payment adjustments, but they would likely be reduced from the maximum upward payment adjustments available to those who participate for the full year.In addition, how this may affect negative payment adjustments was not specified.
Third Option: Full Year Participation in MIPS
Practices the choose this option will be eligible for the full positive 4% payment adjustment based on the 2017 participation year. This is basically the quality payment program as proposed in the April proposed rule. It is assumed that participation in the full year could also result in as much as a 4% negative payment adjustment, however no further details were provided.
Fourth Option: Full Year Participation in an Advanced Alternative Payment Model
This again represents what was stated in the proposed rule. Providers that are able to participate with an advanced alternative payment model for the entire year and meet the volume thresholds may qualify for a 5% positive payment incentive. This would be paid in 2019.
Summary of Changes: The first option states that providers can submit a smaller amount of quality data and still qualify for the quality payment program, but only in the context of avoiding negative payment adjustments. How this would be used to determine the Composite Performance Score was not stated. In addition, specific details on what data needs to be reported will be an important consideration for many practices. It also appear that this would require submission of data for the entire calendar year, starting on January 1, 2017. Without further information being available until November 1st, 2016, this may be a difficult option for many practices to engage.
The second option allows providers to start later in the year or to limit the amount of time they engage with the quality payment program requirements. CMS did state that this could result in a modest bonus, however, they did not specify if this could also result in a modest negative payment adjustment. It is assumed that this reporting period would also be used to determine the composite performance score for the practice or clinician. Perhaps most importantly CMS should declare the exact time frames for reporting, in particular the minimum timeframe. This will impact how practices prepare for 2017. Despited the uncertainty regarding time lines, this would appear to be the most viable option for the majority of practices as it will allow time for preparation. In addition, many EHR and other vendors will likely not be ready for MACRA in early 2017 and this allows them to prepare as well.
The third and fourth option would appear to be unchanged from what was outlined in the proposed rule on MACRA released in April of 2016. A limited number of practices that have achieved high levels of clinical data reporting under PQRS and the MU program may elect to engage in MIPS or an APM for the entire calendar year, making them eligible for upward payment adjustments and bonuses.
Hopefully further details will be released well in advance of the final rule, scheduled to be made available to the public no later than November 1, 2016.
The full text of the CMS blog by Andy Slovitt, Acting CMS Director, is available here.
MACRA FLEXIBILITY IN 2017