The Centers for Medicare and Medicaid Services has proposed a new rule for its Quality Payment Program in an effort to simplify reporting requirements with updates for the second and future years of the program.
In October 2016, CMS published a final rule to implement the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act (MACRA), designed to reward providers for value and improved health outcomes. As part of the program, clinicians have two tracks to choose from—the Merit-Based Incentive Payment System (MIPS) or the Advanced Alternate Payment Models (APMs), based on their practice size, specialty, location or patient population.
The new reimbursement approach in MACRA incorporates payments to reward providers for their use of information technology and data.
“The proposed rule would amend some existing requirements and also contains new policies for doctors and clinicians participating in the Quality Payment Program that would encourage participation in either APMs or the MIPS,” according to the agency’s June 20 announcement.
“Additionally, CMS has used clinician feedback to shape the second year (2018) of the program,” states the announcement. “If finalized, the proposed rule would further advance the agency’s goals of regulatory relief, program simplification, and state and local flexibility in the creation of innovative approaches to healthcare delivery. Moreover, CMS is making it easier for rural and small providers to participate.”
The agency says it is sensitive to stakeholder concerns that small, independent and rural practices in particular are not sufficiently prepared for the Quality Payment Program. By providing additional flexibility in its proposed rule, CMS contends that barriers will be reduced further, enhancing the ability of small practices to participate successfully.
In particular, the rule calls for an increased low-volume threshold that will exempt eligible MIPS clinicians with less than $90,000 in allowed charges or fewer than 200 Medicare Part B beneficiaries from having to participate in the program. The threshold in 2017 was $30,000 in allowed charges or fewer than 100 beneficiaries.
“We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient,” said CMS Administrator Seema Verma in a written statement. “That’s why we’re taking a hard look at reducing burdens.”
When it comes to health IT, CMS proposes reduced burdens and increase flexibility to help clinicians to successfully participate in QPP by continuing to allow the use of 2014 Edition Certified Electronic Health Record Technology, while encouraging the use of 2015 edition CEHRT.
“By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork,” Verma added. “CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.”
Industry groups were quick to respond to the proposed rule with praise for the agency’s flexibility, including the American Medical Association.
“CMS is proposing a number of policies to help physicians avoid penalties under the Quality Payment Program. In particular, it is suggesting several actions to assist small practices,” said AMA President David Barbe, MD. “The administration showed it heard the concerns raised by the AMA on behalf of practicing physicians.”
Barbe pointed out that “not all physicians and their practices were ready to make the leap, and many faced daunting challenges.” However, he believes that CMS’s “flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country.”
Likewise, Tom Nickels, executive vice president of the American Hospital Association, said AHA was “encouraged by CMS’s proposal for a facility-based clinician reporting option that may promote better alignment and collaboration on efforts to improve quality among hospitals and clinicians.”
In particular, Nickels applauded CMS’s proposal to “provide much-needed relief from unrealistic, unfunded mandates for EHR capabilities by extending the use of modified Stage 2 Meaningful Use requirements through 2018,” and he encouraged the agency to “provide the same relief to hospitals.”
AHA also encouraged CMS to provide additional opportunities for clinicians to earn incentives for partnering with hospitals to provide better quality, more efficient care through advanced alternative payment models.
“We will review the details of the proposed rule and will provide input to the agency to help ensure CMS’s polices enable patients to benefit from the transformation of care envisioned by MACRA,” Nickels concluded.
CMS will accept comments on the proposed rule until 5 p.m. on August 21. However, not all industry groups responded favorably to the agency’s proposed rule.
While the American Medical Group Association said it recognizes the burden MACRA places on small practices and appreciates the options for them to participate, it said it’s concerned that the proposed rule delays the transition to value and does not recognize the investment that its members have made in preparing for a value-based healthcare system.
“If CMS wants to transition to value-based payment for care, the program needs to be fully implemented,” said Chester Speed, AMGA’s vice president for public policy. “We recommend that CMS revise its proposal to fully incentivize high performers in the Medicare program.”
Specifically, AMGA said it welcomes CMS’ invitation to provide comment on options to allow clinicians’ contracts with Medicare Advantage plans that meet the risk, quality and certified EHR technology requirements to be included under the beneficiary count test for the 5 percent APM bonus in 2019 and 2020.
“CMS has an opportunity to revise this proposal to reflect Congress’ intent to move the Medicare system to one that rewards results,” Speed added. “AMGA members have already started on this journey, and they should be recognized for being leaders in healthcare.”
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