The intent of CMS / MACRA was not to push the smaller practice to join hospitals or larger practices. Knowing they need to better define the requirements and help providers in the transition to a new value based program, CMS has added reporting options to the Quality Payment Program MIPS track, allowing eligible clinicians to choose their own pace.
The good news is that the Quality Payment Program will not require a full year of reporting in the first performance year 2017.
Under Quality Payment Program – MIPS Track –
- Option 1. ECs can submit data to the Quality Payment Program – MIPS track, including data from after January 1, 2017 – avoids the negative payment adjustment
- What we don’t know:
- How much data?
- From one performance category or more than one?
- Any data with now reporting period quota?
- What we don’t know:
- Option 2. ECs participate for part of the calendar year, for a reduced number of days – the potential to receive a positive adjustment
- What we don’t know:
- What is “reduced number of days” – 30 days, 60 days, 90 days
- Is participation expected in all 4 performance categories – there is mention of choosing Quality measures and improvement activities
- Can they submit only quality measures – because this conflicts with Option 3 submitting Quality for a full year
- What we don’t know:
- Option 3. ECs submit information for the entire 2017 year on Quality measures – “could” qualify for a modest positive adjustment
Under APMs
QPs (clinicians meeting the Medicare payments or patient percentages in an Advanced APM) in an Advanced APM in 2017 will qualify for a 5% incentive.
No matter what is decided on the 2017 performance period, Medicare part B providers should except that MACRA / QPP / MIPS/APMs will be the new payment program in 2017. Adjusting dates and reporting periods is great, however their continues to be many questions, especially on the proposed reporting metrics determining the payment (positive / negative) adjustments for MIPS. We expect the details will most likely emerge in the final rule predicted to be released in November.
