On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment period to implement MACRA's new Quality Payment Program (QPP). The program begins in 2017, with payment adjustments beginning in 2019. Providers can "pick their pace of participation" by choosing one of the following four options during 2017 transition year to avoid a negative payment adjustment in 2019:
If a provider submits a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity or the required ACI base measures), they could avoid a downward payment adjustment in 2019.
If a provider submits 90 continuous days of 2017 data to Medicare (for example, more than one quality measure or more than one improvement activity or the required ACI measures), they may earn a neutral or small positive payment adjustment in 2019.
If a provider reports all required measures for a full year, they may earn a moderate positive payment adjustment in 2019.
If providers receive 25% of their Medicare covered professional services, or see 20% of their Medicare patients, through an APM in 2017, they could qualify for incentive payments in 2019.
*Only eligible clinicians who choose not to report any data during the 2017 transition year would receive the 4% penalty in 2019 (unless they fall under one of the exemptions).
To check if you need to submit 2017 MIPS data, please visit the CMS Quality Payment Program website.
Individual clinicians and groups would have various options to submit their MIPS data to CMS:
Quality: Qualified Registry (such as MDinteractive), Qualified Clinical Data Registry (QCDR), EHR and Administrative Claims (no submission required)
Advancing Care Information: Qualified registry, QCDR, EHR and Attestation
Clinical Practice Improvement Activities: Qualified registry, QCDR, EHR, Attestation and Administrative Claims (if technically feasible; no submission required)
Cost: Administrative Claims (no submission required). Note that this category will not be "counted" in 2017 but providers will still receive a QRUR report (when feedback reports are distributed in Fall 2018) to give them information on how they would have performed.
Quality: Qualified registry (such as MDinteractive), QCDR, EHR, CMS Web Interface (groups of 25 or more), CAHPS for MIPS Survey (must be reported in conjunction with another data submission mechanism), and Administrative Claims (no submission required)
Advancing Care Information: Qualified Registry, QCDR, EHR, CMS Web Interface (groups of 25 or more) and Attestation
Clinical Practice Improvement Activities: Qualified registry, QCDR, EHR, Attestation, CMS Web Interface (groups of 25 or more) and Administrative Claims (if technically feasible; no submission required)
Cost: Administrative Claims (no submission required)
GPRO reporting - GPROs will no longer have to formally register with CMS as groups to submit data using third party entities, such as qualified registry, health IT vendor, or QCDR. When one of these entities submits data for a group, CMS is able to obtain group information from the third party and determine if the data submitted represents group submission or individual submission. CMS may establish a voluntary registration process in the future.
The final rule provides incentives for eligible clinicians who participate in eligible advanced APMs. Advanced APMs must meet three requirements:
Required use of certified EHRs
Payment based on quality measures comparable to MIPS
The APM either requires APM entities to bear more than “nominal” financial risk for losses or meet the criteria for an expanded Medical Home Model
Further information can be found at: