While the implementation of the Quality Payment Program (QPP) within the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) may seem daunting, the program does offer some data capture and reporting relief to practices.
MACRA takes elements from three existing Centers for Medicare and Medicaid Services’ (CMS) programs—the Physician Quality Report System (PQRS), the Electronic Health Record Incentive Program (commonly known as Meaningful Use or MU) and the Value-Based Modifier (VBM)—and consolidates them to one QPP avenue: the Merit-based Incentive Payment System (MIPS). This means that practices have less overall data to capture, track and report.
Succeeding in the QPP may still be challenging, but we have identified four reasons your practice may find some liberation in the changes:
1. Quality measures are fewer and are likely more familiar to physicians
2. Advancing Care Information reduces MU requirements
3. Clinical Practice Improvement Activities category offers more flexibility
4. Health Information Technology allows for simplified reporting
1. Quality Measures Are Fewer and Are Likely More Familiar to Physicians
Most physicians will participate in MIPS unless they qualify as practicing under an Advanced Alternative Payment Model (APM). There is a limited number of Advanced APM participants, which is comprised mostly of Medicare-managed programs such as the Medicare Shared Savings Program, CMS Next Generation Accountable Care Organization, Comprehensive End-Stage Renal Disease Care Model and others.
MIPS has four categories: Quality, Clinical Practice Improvement Activities (CPIA), Advancing Care Information (ACI) and Cost. The Cost category will not be counted in 2017 and will be based on submitted Medicare claims in 2018 and beyond. For this reason, it will not require reporting from providers.
The Quality measures will likely be familiar to physicians who participated in PQRS. CMS has also outlined specialty measure sets to further ease the burden for providers. However, unlike PQRS, which required reporting nine measures across three domains, MIPS requires physicians to report six quality measures with one outcome measure for a period ranging from 90 days to a full year in 2017 and 2018.
Physicians can select from 271 quality measures to report in the Quality category. While not all metrics will be applicable to all specialties, finding six relevant measures should be highly feasible. In addition, CMS has outlined specialty measure sets to ease the burden for providers.
2. Advancing Care Information Reduces MU Requirements
Under ACI, which incorporates many elements from MU, physicians are only required to report five measures—which count for 50 points—for a minimum 90-day period in 2017. This is scaled down from the 10 objectives that physicians were required to report for MU.
Physicians can submit four additional measures (for a total of nine measures) to earn up to 90 additional points for performance to count toward the 100 needed for full credit in the ACI category. Reporting data to public health registries and using a certified electronic medical record (EMR) also earns up to 15 extra points.
3. Clinical Practice Improvement Activities Category Offers More Flexibility
A new category, CPIA, requires practices with 15 or fewer physicians to attest that the practice completed two CMS-designated initiatives focused on care coordination, patient engagement and safety for a minimum 90-day period. Larger organizations need to attest for four activities.
CMS allows physicians to choose from 92 activities for attestation, which will likely make matching an internal practice improvement effort with one of the MIPS options relatively simple. Furthermore, physicians have an option to select highly weighted measures to double points earned. In turn, this will reduce the total number of required activities.
4. Health Information Technology Allows for Simplified Reporting
Selecting a certified EMR that can automatically capture required MIPS data can streamline reporting to further simplify program participation. It is beneficial to choose an EMR that was designed for your specialty, can be customized for your practice and has Quality metrics, Improvement Activities and ACI capabilities pre-loaded into the system for the best attestation and reporting experience.
Ensuring your practice’s information technology partner is prepared for the QPP is only the first step. It is crucial to get started sooner rather than later in order to minimize time and energy spent on program participation, as well as financial penalties from CMS.