While the Centers for Medicare and Medicaid Services has made significant progress towards implementing its new Quality Payment Program, meant to reward providers for value-based care, there are vulnerabilities that CMS must addressed next year if the program is to succeed.

That’s the conclusion of a Department of Health and Human Services Office of the Inspector General audit which identified two vulnerabilities that are critical for CMS to address in 2017, including providing sufficient guidance and technical assistance to ensure that clinicians are ready to participate in the Quality Payment Program (QPP), as well as developing IT systems to support data reporting, scoring and payment adjustment.

CMS issued final regulations on October 14; the first performance year will begin Jan. 1, 2017, with the first payment adjustments taking effect on Jan. 1, 2019.

The QPP is part of the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) and thus will involve Medicare Part B payments for about 600,000 clinicians. To participate, clinicians have two tracks from which to choose from—the Merit-Based Incentive Payment System (MIPS) or the Advanced Alternate Payment Models (Advanced APMs).

“As of December 2016, CMS had finalized key policies to implement the QPP, including issuing final regulations and identifying Medicare models that qualify as Advanced APMs for the first performance period,” the OIG’s report notes. “CMS had also initiated engagement and outreach activities to clinicians, launched a public-facing informational website, and awarded various contracts for technical assistance and training.”

However, auditors also reported that CMS “must still expand its technical assistance efforts, issue promised sub-regulatory guidance, award and oversee key contracts, and complete development of backend IT systems necessary to support critical QPP operations.”

In particular, the OIG noted that CMS “faces challenges in building the complex backend IT systems required to receive clinicians’ data, calculate their MIPS scores, and carry out other functions vital to the program’s success.”

Also See: Value-based payment poses challenges for small, rural practices

According to auditors, building and testing the extensive IT systems necessary to support critical QPP operations will require significant and sustained effort over the upcoming year. Some key functions must be operational in 2017, while others will be required in 2018. However, “if the complex systems underlying the QPP are not operational on schedule, the program will struggle to meet its goal of improving value and quality,” warned the OIG.

A CMS spokesperson declined to specifically comment on the OIG’s findings and recommendations, and instead referred to the agency’s official written response published in the audit report.

In its written comments submitted to the OIG, CMS stated it is “committed to continuing to engage with and provide assistance to clinicians, and to optimize backend IT systems support, as it implements the Quality Payment Program.”

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