CMS recently finalized its policy implementing the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (APM) incentive payment provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), collectively referred to as the Quality Payment Program.
The new Quality Payment Program will gradually transform Medicare payments for more than 600,000 clinicians across the country, and is a major step in improving care across the entire health care system.
Join Kentucky REC on Friday, November 4th at 11:00am for an overview of the new MACRA Final Rule.
The Kentucky REC is launching a brand new service offering in November, the Patient-Centered Medical Home (PCMH) and Patient Centered Specialty Practice (PCSP) Fast Track Program. Based on the success of our PCMH/PCSP Cohort, this program is designed to accelerate your journey to NCQA PCMH/PCSP Recognition within a nine month period. Through our expert training, coaching, and resources your staff will be well-prepared to achieve recognition in time to receive full CPIA credit for MIPS and submit for PCMH 2014 before the standards are updated to the 2017 version.
The PCMH/PCSP Fast Track Program will kick-off on November 3, 2016, so please let us know ASAP if you are interested in joining!
To learn more about PCMH, PCSP, and the Fast Track Program, listen to our webinar recording here.
In 2017, CMS will apply a negative payment adjustment to individual eligible professionals (EPs), Comprehensive Primary Care (CPC) practice sites, and group practices participating in the Physician Quality Reporting System (PQRS) group practice reporting option (GPRO), including Accountable Care Organizations (ACOs) that did not satisfactorily report PQRS in 2015.
EPs, CPC practice sites, PQRS group practices, and ACOs that believe they have been incorrectly assessed the 2017 PQRS negative payment adjustment may submit an informal review between September 26, 2016 and November 30, 2016 requesting CMS investigate payment adjustment determination. All informal review requestors will be notified via email of a final decision by CMS within 90 days of the original request for an informal review. All decisions will be final and there will be no further review.
If you have any questions regarding the status of your 2015 PQRS reporting or are concerned about potentially receiving the PQRS negative payment adjustment in 2017, please do not hesitate to submit an informal review request. CMS will be in contact with every individual EP or PQRS group practice that submits a request for an informal review of their 2015 PQRS data.
Follow these steps to submit an informal review request:
1. Go to the Quality Reporting Communication Support Page (CSP)
2. In the upper left-hand corner of the page, under “Related Links,” select “Communication Support Page”
3. Select “Informal Review Request”
4. Select “PQRS Informal Review”
5. A new page will open
6. Enter Billing/Primary Taxpayer Identification Number (TIN), Individual Rendering National Provider Identifier (NPI), OR Practice Site ID # and select “submit”
7. Complete the mandatory fields in the online form, including the appropriate justification for the request to be deemed valid. Failure to complete the form in full will result in the inability to have the informal review request analyzed. CMS or the QualityNet Help Desk may contact the requestor for additional information if necessary.
Please see “2015 PQRS: 2017 PQRS Negative Payment Adjustment – Informal Review Made Simple” available on the PQRS Analysis and Payment webpage for more information.
Contact the Kentucky REC for help or additional information.
The Kentucky REC team is busily dissecting the MACRA Final Rule for Kentucky providers. We will be providing an analysis and holding a webinar for providers soon. Make sure to sign up for our regional seminars in the coming weeks – we’ll have a user friendly overview of MACRA at those events.
In the meantime, here’s our summary of the major changes to the new Quality Payment Program:
• Pick your pace. Providers now have five options in Year 1 with graduated rewards or penalties:
- Don’t participate (subject to the full 4% penalty in Medicare payments in 2019),
- Send some data for at least one measure (no penalty, no bonus)
- Send partial data for a 90 day reporting (more than 1 measure) (no penalty, some bonus possible)
- Participate fully for a full year (no penalty, larger bonus possible)
- Participate in an Alternative Payment Model (no penalty, even larger bonus possible)
• Quality counts. Quality is now 60% of the composite performance score and resource use is reduced to 0% for the first year. Other category scoring is unchanged. Individual clinicians and groups report 6 quality measures (if participating in the full year option). CMS clarified that groups using the CMS web interface need to submit the 15 quality measures CMS has selected for a full year.
• It’s easier to NOT qualify. An “Eligible Clinician” is still a physician, a physician assistant, a nurse practitioner, a clinical nurse specialist or a certified registered nurse anesthetist participating in Medicare. However, the low volume threshold has been adjusted in the final rule. So, among these providers, those who do not bill at least $30,000 a year under the Medicare Physician Fee Schedule or provide care for more than 100 Medicare patients a year are exempt. First year Medicare participating clinicians are also exempt.
• The grading curve has changed substantially. CMS has stated that in 2017 the performance threshold will be lowered to 3 points out of 100 for not receiving a penalty. Still want to be an overachiever? You can do more than the minimum and potentially qualify for larger bonuses. Clinicians who achieve a final score of 70 or higher will be eligible to split an exceptional performance pool of $500 Million.
• A rose by another name still has thorns. Advancing Care Information requirements (which is the new name for what was formerly Medicare Meaningful use) were reduced to just 5 required measures – perform an annual Security Risk Assessment, use e-prescribing, ensure Patient Access, exchange Summary of Care information and Request or Accept Summary of Care information. But you can also submit up to 9 measures for 90 days for additional credit. We are reviewing the health information exchange requirements and still think these will be a sticking point. (Pun intended.)
• Improvement Activities – the name and the requirements are shorter. Requirements were reduced from 6 down to just 2-4 activities for at least 90 days. Providers in rural or health professional shortage areas and non-patient facing providers must only do 1-2 improvement activities. Certified medical home practices can get full credit automatically in this category, as do APM participants eligible for special scoring (e.g., Track 1 and Oncology Model participants). Other APM participants get at least half credit under this category. If using PCMH certification for this category, at least one practice for the group must be certified with a medical home organization that meets CMS outlined criteria.
• New Advanced APM options coming soon! Beginning in 2018, MSSP ACO Track 1+, the Cardiac & Joint Care Episode Payment Model and a new Voluntary bundle option will also be eligible for 5% advanced APM bonus. As previously specified in the proposed rule, participants in 2017 for the following options of CPC+, ESRD Model, MSSP Track 2 & 3, and Next Generation ACO could qualify for the 5% advanced APM bonus in 2019.
We know, we know – all these new words and acronyms sometimes sound like Greek to us, too. Hang in there – help is on the way. The Kentucky REC team is working on a user-friendly translation of the 2300+ page final rule. Stay tuned for more!
On Friday, the Department of Health and Human Services (HHS) finalized its policy implementing the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (APM) incentive payment provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), collectively referred to as the Quality Payment Program. The new Quality Payment Program will gradually transform Medicare payments for more than 600,000 clinicians across the country, and is a major step in improving care across the entire health care system.
The final rule with comment period offers a fresh start for Medicare by centering payments around the care that is best for the patients, providing more options to clinicians for innovative care and payment approaches, and reducing administrative burden to give clinicians more time to spend with their patients, instead of on paperwork.
Accompanying the final rule is a new Quality Payment Program website, which will explain the new program and help clinicians easily identify the measures most meaningful to their practice or specialty.
To see the press release and obtain more information please click here.
Download the QPP Final Rule Fact Sheet