With 2017 upon us, many practices are scrambling to understand the Quality Payment Program final rule. The final rule was published on October 14, 2016 with CMS making significant revisions to the proposed rule. In the final rule, CMS increased the flexibility of the Medicare Access and CHIP Reauthorization Act (MACRA) by introducing an option-based implementation plan, titled “Pick Your Pace,” which allows providers to ease into MACRA for the 2017 reporting year.
While this wasn’t a full on delay that the American Medical Association (AMA) was asking for, it does allow clinicians to have a bit more time to prepare and avoid penalties if they demonstrate the ability to at least report some data for a minimum of 90 days in 2017.
When it comes to participating in the Merit Based Incentive Payment System in 2017, Eligible Providers have five different options.
1. Don’t participate – If you don’t send in any 2017 data, then you will receive a negative 4% payment adjustment
2. Test the Quality Payment Program – Testing the program by submitting a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity at any point in 2017), allows you to avoid a downward payment adjustment. This option is designed to ensure that your system is working and that your practice is prepared for broader participation in 2018 and 2019 as you learn more.
3. Participate for part of the calendar year – You may choose to submit Quality Payment Program information for a reduced number of days (Any consecutive 90 day period). Therefore, your first performance period could begin later than January 1, 2017, and your practice could still qualify for a small positive payment adjustment.
4. Participate for the full calendar year – For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. By submitting the full year of 2017 data to Medicare, you may earn a modest positive payment adjustment.
5. Participate in an Advanced Alternative Payment Model – Instead of reporting quality data and other information; the law allows clinicians and practices to take part in the QPP by joining an Advanced APM, such as a Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced APM Model in 2017, then you would qualify for a 5% incentive payment in 2019.
Even though these options sound like a good thing, clinicians, and practices who choose not to report a full year, or participate in an Advanced APM are only putting themselves behind.
The Upside of Reporting a Full Year or Participating in an Advanced APM
There is a significant potential for additional revenue with MACRA’s Quality Payment Program (QPP), which begins on January 1, 2017. The program includes two different payment pathways: the Merit-based Incentive Payment System and the (Advanced APMs).
With MIPS, providers can earn a 4% bonus on top of their Medicare fee schedule in 2019, which is based on 2017 performance. This bonus gradually increases to 9% for the payment year 2022 and beyond.
Furthermore, this bonus could be increased up to a multiple of 3 if the percentage of clinicians receiving penalties is higher than those receiving bonuses (Budget-Neutrality Factor). Finally, exceptional performers in MIPS can receive additional bonuses of up to 10% on top of their initial performance bonuses. With Advanced APMs, clinicians and practices can receive a 5% lump sum bonus in addition to potential bonuses available through the APM’s themselves.
The Downside of Taking a Lesser Approach
There is also an enormous potential for money to be lost with MACRA’s QPP. Clinicians, who are the lowest performers, or those who decide against participating, will receive a -4% penalty in 2019, which will increase to -9% in 2022. Because MACRA is budget neutral, this means that those penalties will be going directly into the pockets of the high performers of MIPS.
So, When Should You Start?
All things considered, clinicians and practices should do their best to start reporting for MACRA’s Quality Payment Program beginning January 1 of 2017.
Even though there are options to take a lesser approach, these options will not serve you well in the future. Let’s take, for example, the recent transition to ICD-10 and the move to electronic health records (EHRs). There were plenty of delays in these implementation deadlines, which allowed clinicians to put off fully committing to the changes.
Once there were no more delays, and full implementation was required, many clinicians had a tough time meeting the new deadlines and were far behind other clinicians who took the time early on to understand the necessary requirements.
Clinicians and practices that fully commit to MACRA’s QPP and act as if there are no options to pick their pace will be in a far better position to secure bonuses in the later years of MACRA reporting. Clinicians and practices that do only the minimum, or do nothing at all, will be at a significant disadvantage moving forward.
A great analogy for this program is to imagine it like a treadmill that is continuously increasing. Those who are on the treadmill early will have an easier time with the increasing speed. However, those who try to jump on later will have a much harder time adjusting to the speed and will have a difficult time catching up to those early starters.
Clinicians and practices should take note of past incentive programs that delayed implementation. Typically, when implementations are delayed by CMS, it is an indication that the program is necessary and also challenging.
These delays (or options to pick your pace) are not time buffers to push back implementation, but instead, an extension meant for clinicians to test the programs and understand them before the penalties become too drastic for clinicians and practices to handle. By moving forward as if there is no other option but to implement the QPP in full is by far the best thing clinicians and practices can do, which will greatly benefit them in future years the QPP.