As the new year begins, the MACRA law and its Quality Payment Program (QPP) are on the minds of many physicians and health care executives. The year 2017 is a transitional year for the QPP.
Medicare is allowing physicians to pick the pace at which they participate, as part of the QPP’s Merit-based Incentive Payment System (MIPS) or through an Advanced Alternative Payment Model (APM).
We discussed five options physicians and group practices have with Erik Johnson, Optum Vice President for Health Management Consulting.
1. The Centers for Medicare and Medicaid Services (CMS) is allowing physicians the opportunity to test the MIPS waters. What are the benefits of doing that?
Medicare administrators understand that the MACRA law represents a sea change for physicians and many aren’t ready for it. In response, Medicare created a method where physicians could submit a minimal amount of data to avoid a negative payment adjustment.
To qualify for the “test” pace, physicians need only submit one quality measure and one improvement activity.
It’s a good compromise that keeps physicians from losing a significant chunk of revenue while following the spirit of the MACRA law, which is to move Medicare Part B payment to value-based reimbursement.
2. What about physicians who want to do more than avoid penalties but who aren’t prepared to report to CMS 12 months’ worth of data?
Medicare has set up a separate MIPS track for physicians and groups who may not be ready to report for the entire year. These physicians can submit QPP information for 90 days.
Going this route may earn them a small positive adjustment in Part B payments, but it’s also likely that payment will remain neutral.
3. What sort of benefits could physicians receive if they reported though MIPS for all of 2017?
Participating in MIPS for the entirety of this year will earn physicians a larger percentage bonus than participating for only 90 days. But the percentage will likely be about 1 percent.
A subsection of physician groups in both the 90-day and full-year reporting programs will receive exceptional performer bonuses. But while groups could receive some hefty bonuses, they will represent a disproportionately small percentage of MIPS participants.
4. The QPP also includes Advanced APM organizations. What sort of benefits can they expect?
Physicians who participate in an Advanced APM in 2017 — meaning they have a large enough percentage of their patients covered by a Medicare Advanced APM that includes downside risk, such as certain types of Medicare ACOs — will receive a 5 percent incentive payment in 2019.
That’s on top of the shared savings revenue they may receive unrelated to the bonus. It’s also true, however, that they may be on the hook for shared losses in an Advanced APM. But overall, Advanced APMs offer a much more definable and stable path to revenue.
5. What if physicians follow a fifth option — they decide to not participate?
We need to be clear that not all physicians who accept Medicare will be required to participate in the QPP.
First-year participants in Medicare, physicians who bill less than $30,000 a year to Medicare or who provide care to less than 100 Medicare beneficiaries will not be paid via the QPP.
Those who do qualify to participate yet do not report will receive a negative payment adjustment of 4 percent. Physicians who qualify for the QPP should at least report one quality measure and one improvement activity to keep from being penalized 4 percent.
Regardless which MACRA path you choose, measurement is key. Click here to learn about developing quality data sets.
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