The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established the Quality Payment Program (QPP). QPP transitions Medicare payment away from fee-for-service to pay-for-performance, emphasizing quality care. The program represents a significant change in the way all physicians, including radiation oncologists, will be paid by Medicare.
Participation in the QPP is through one of two pathways:
Most physicians will be participating in the MIPS “Pick Your Pace” program in 2017. The “Pick Your Pace” program recognizes the complexity of the QPP and provides physicians with some flexibility to participate in the MIPS program at different levels based on their readiness. MIPS combines and replaces the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM) and Medicare EHR Incentive (Meaningful Use) programs into one comprehensive program. The MIPS program involves four performance categories: Quality, Advancing Care Information (ACI), Improvement Activities and Cost.
Radiation oncologists can avoid a negative payment adjustment in 2019 by submitting a minimum amount of data for the 2017 reporting period. Radiation oncologists can utilize two of ASTRO’s programs, RO-ILS and APEx, to help meet the Improvement Activities category, and they can help meet the Quality category by submitting data on quality measures through ASTRO’s MIPSwizard.
Eligible clinicians who choose not to comply with MIPS during the 2017 performance period are subject to a 4 percent payment reduction in 2019.
Don’t ForgetClinicians still need to meet PQRS and Meaningful Use reporting requirements in 2016 for a payment adjustment in 2018. The reporting deadline for 2016 PQRS data using ASTRO’s PQRSwizard is March 17, 2017, at 5:00 pm EST. Attestations for the 2016 Meaningful Use program year must also be submitted by March 13, 2017.
The Quality Payment Program (QPP) establishes two possible pathways to participate in QPP, the Merit Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) program. MIPS replaces Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM), and Medicare EHR Incentive (Meaningful Use). MIPS is divided up into four performance categories: Quality, Advancing Care Information (ACI), Improvement Activities and Cost. The APM program allows physicians to participate in payment models that promote value over volume and provide incentives for physicians to deliver high-quality healthcare.
As established by the Medicare Access and CHIP Reauthorization Act (MACRA), QPP aims to simplify quality reporting and change the way clinicians receive Medicare payment. This change emphasizes quality of care over quantity of services. Based on performance in the 2017 reporting period, 2019 Medicare Part B payments will vary between -4 and +4 percent, with the possibility of an exceptional performance bonus of +10%. The potential for larger penalties and bonuses increases in future years.
All eligible clinicians who report $30,000 in Medicare services and provide care for more than 100 Medicare patients a year are subject to QPP. Eligible clinicians include physicians, physician assistants, nurse practitioners and clinical nurse specialists.
The 2017 reporting period is January 1 to December 31, 2017. But for the 2017 transition year, eligible clinicians can choose how they will participate in the MIPS program under the “Pick Your Pace” program. “Pick Your Pace” allows clinicians to report none, some or significant amounts of data and provides flexibility as to when data collection needs to begin.
As with previous Medicare programs, there is a program cycle consisting of performance measurement, feedback, and payments adjustments.
The first performance period opens January 1, 2017 and closes December 31, 2017. During the 2017 performance period, physicians or groups record quality data for the elements of each MIPS category in which they participate. If the practice is participating in an Advanced APM, such as the Oncology Care Model, then physicians or groups can join and provide care during the year through that model and do not need to report under MIPS.
To potentially earn a positive payment adjustment under MIPS, physicians or groups send in data on care provided and the elements of each MIPS performance category in 2017 to CMS by the deadline, March 31, 2018. In order to earn the 5% incentive payment by significantly participating in an Advanced APM, such as the Oncology Care Model, physicians or groups send quality data through the Advanced APM to CMS.
During 2018, CMS will provide feedback about performance based on the submitted data.
Physicians or groups may earn a positive MIPS payment adjustment for 2019 based on 2017 data submitted by March 31, 2018. If physicians or groups participate in an Advanced APM in 2017, then they may earn a 5% incentive payment in 2019.