Quality Payment Program
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, are paid by Medicare.
Participation in the QPP is split between the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM); however, within those two branches there is a lot of variation. ASTRO has found that many radiation oncology practices fall into a middle ground of MIPS APMs, which include Accountable Care Organizations (ACOs). The following pages provide a deeper dive into the details of each model:
CMS evaluates eligibility based on where a practice has reassigned billing rights in the Provider Enrollment, Chain, and Ownership System (PECOS). ASTRO recommends that all practices confirm information in PECOS annually.
Physicians can look up eligibility and reporting requirements on the QPP website using their National Provider Identification (NPI) number. Information will include CMS’s analysis of the number of Tax Identification Numbers (TINs) associated with your NPI including MIPS eligibility, APM enrollment, hospital-based designation (more than 75% of services are billed at the hospital), and small practice designation (15 or less eligible clinicians). This information will be provided for both the individual (NPI) and group-level (TIN). This is a valuable resource to determine clinician specific program requirements, as well as ensure that CMS has the correct information regarding your practice.
To date there have been three program years with varying requirements.
- 2019 – While the majority of previous year’s program basics remain the same —including the use of RO-ILS and APEx to meet the Improvement Activities category and the ability to utilize the QOPI Reporting Registry for data collection and submission—there are a number of significant changes. The new performance year continues to increase the program requirements. Eligible clinicians who choose not to comply with MIPS during the 2019 performance period are subject to a 7% payment reduction in 2021.
- 2018 – Review ASTRO’s 2018 Overview to learn more about the differences between the 2017 and 2018 program years. Radiation oncologists will need to do more in 2018 than in 2017 to avoid the negative payment adjustment. Eligible clinicians who choose not to comply with MIPS during the 2018 performance period are subject to a 5% payment reduction in 2020.
- 2017 – Physicians and practices were allowed flexibility in the first year of the program through the “Pick Your Pace” program. The “Pick Your Pace” program allowed physicians to participate in the program at different levels based on their readiness. Eligible clinicians who chose not to comply with MIPS during the 2017 performance period are subject to a 4% payment reduction in 2019.
Score and Payment Attribution
QPP is a complex program, and help is necessary to understand all of the elements and succeed.
Quality Oncology Practice Initiative (QOPI®) Reporting Registry brought to you by ASCO and ASTRO is now available! This Qualified Clinical Data Registry (QCDR) supports continuous quality improvement that meets federal quality programs.
Many radiation oncology practices will fall into the MIPS program. MIPS requirements change each year and radiation oncologists need to stay up to date to avoid the penalty.
MIPS APMs and ACOs
Many radiation oncology practices may be part of Accountable Care Organizations that have different reporting requirements under the Quality Payment Program.
Advanced Alternative Payment Models
APMs require physicians to take on risk and responsibility for their own cost and quality performance. Participants are eligible for a 5 percent incentive payment for participating in an Advanced APM.
ASTRO is committed to developing quality measures that are meaningful and relevant to radiation oncologists through independent development efforts. ASTRO’s goal is to continue incorporating these measures into the MIPS program.
ASTRO Comments on proposed RO Model
While ASTRO appreciates CMS’ decision to move forward with an alternative payment model for radiation oncology and believes there are some positive elements in the proposed Radiation Oncology Model (RO Model), we are concerned that the proposal falls short of meeting key goals established by ASTRO for the successful development of an alternative payment model.
CMMI Issues Report on RO-APM
The Centers for Medicare and Medicaid Innovation Center (CMMI) issued a report to Congress on Episodic Alternative Payment Model for Radiation Therapy Services in compliance with the ASTRO supported Patient Access and Medicare Protection Act.
2020 QPP Final Rule Summary
On Friday, November 1, 2019, CMS issued the 2020 Quality Payment Program (QPP) final rule that includes updates to the current program and a new Merit-Based Incentive Payment System (MIPS) Value Pathways framework.