On September 8, Andy Slavitt, acting administrator of the Centers for Medicare & Medicaid Services (CMS) announced new flexibility for eligible clinicians to meet the requirements of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA repealed the Sustainable Growth Rate formula, and created new payment methods for clinicians.
Although the final rule is not yet complete, the first reporting period under MACRA is set to begin January 1, 2017, and the first reimbursement adjustment for physicians under the program based on that reporting period would be in 2019. WHA and other organizations had expressed significant concern about the short implementation time frame and the significant learning curve and thus the ability of clinicians to avoid payment penalties under the program. WHA had the opportunity to express these views at an in-person meeting with Acting Administrator Slavitt in June.
Using the umbrella term, Quality Payment Program (QPP), Slavitt said yesterday that clinicians will be able to “pick their pace” of participation by choosing among four options, with one of those options designed to ensure the clinician would not face a payment penalty in the first year. The four options as described by CMS are:
First Option: Test the Quality Payment Program.
As long as the clinician submits some data to the Quality Payment Program, including data from after January 1, 2017, the clinician will avoid a negative payment adjustment. This option is designed to ensure that the clinician’s system is working and that the clinician’s practice is prepared for broader participation in 2018 and 2019.
Second Option: Participate for part of the calendar year.
The clinician may choose to submit Quality Payment Program information for a reduced number of days. This means the first performance period could begin later than January 1, 2017 and the clinician’s practice could still qualify for a small positive payment adjustment.
Third Option: Participate for the full calendar year.
For practices that are ready to go January 1, 2017, data may be submitted for a full calendar year. This means the first performance period would begin January 1, 2017, and the clinician could qualify for a modest positive payment adjustment. CMS indicates that it has seen physician practices of all sizes successfully submit a full year’s quality data, and expects many will be ready to do so.
Fourth Option: Participate in an Advanced Alternative Payment Model in 2017.
Instead of reporting quality data and other information, the law allows participation in the QPP by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If the clinician receives enough Medicare payments or sees enough Medicare patients through such a model in 2017, the clinician could qualify for a five percent incentive payment in 2019.
Additional details will be described more fully in the final rule, which CMS indicates will be released by November 1, 2016. WHA has already held one webinar on the part of MACRA called the Merit-Based Incentive Program (MIPS). A second webinar focusing on the Advanced Alternative Payment Models will be held later this fall. Information about this webinar will be shared in a future edition of The Valued Voice
The notice from CMS regarding these four options for participation can be found here