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 through one of two pathways:

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, Promoting Interoperability (PI), Improvement Activities (IA) and Cost.

To date there have been two program years with varying requirements.

2017 – Physicians and practices were allowed flexibility in the first year of the program through the “Pick Your Pace” program. Recognizing the complexity of MIPS, the “Pick Your Pace” program allowed physicians to participate in the program at different levels based on their readiness. In 2017, radiation oncologists could avoid a negative payment adjustment in 2019 by submitting a minimum amount of data for the 2017 reporting period. Two of ASTRO’s programs, RO-ILS and APEx, were available to help radiation oncologists meet the Improvement Activities category. The Quality Oncology Practice Initiative (QOPI^®) Reporting Registry brought to you by the American Society for Clinical Oncology (ASCO) and ASTRO, allowed radiation oncologists to report all performance categories. Eligible clinicians who chose not to comply with MIPS during the 2017 performance period are subject to a 4 percent payment reduction in 2019.

2018 – While the majority of the 2017 program basics remain the same for the 2018 performance year—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. 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 percent payment reduction in 2020.

Performance and Payment Cycle

As with previous Medicare programs, there is a program cycle consisting of performance measurement, data submission, feedback, and payment adjustments.

Performance:

The 2017 performance period opened January 1, 2017, and closed December 31, 2017. The 2018 performance cycle runs from January 1, 2018, to December 31, 2018. During each of these performance periods, physicians or groups record data for the elements of each MIPS category in which they participate. If the practice is participating in an Advanced APM, such as the two-sided risk version of the Oncology Care Model (OCM), then physicians or groups can join that model during the year and do not need to report under MIPS.

Submit performance data:

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 to CMS by the deadline, March 31 following the close of the performance year. For the 2018 performance year, data must be sent to CMS by March 31, 2019. For practices participating in an Advanced APM, such as the OCM (two-sided risk), physicians or groups send quality data through the Advanced APM to CMS.

Feedback:

CMS will provide feedback about performance based on the submitted data in the year following the performance year.

Payment:

Physicians or groups may earn a positive MIPS payment adjustment based on submitted data two years after the performance period. If physicians or groups participate in an Advanced APM, then they may earn a 5 percent incentive payment two years after the performance year.

Year	Date	Important Deadline
2017	January 1	2017 performance period began
	October 2	Last chance to start 90-day reporting period
	December 31	2017 performance period ended
2018	January 1	2018 performance period began
	March 31	Deadline to submit 2017 performance data
	Fall	CMS feedback provided to clinicians for 2017 performance data
	October 2	Last change to start a 90-day reporting period
	December 31	2018 performance period ends
2019	January 1	2019 performance period begins
	March 31	Deadline to submit 2018 performance data
	Spring	2017 payment adjustments implemented (+/- 4 percent)
	Fall	CMS feedback provided to clinicians for 2018 performance data
	December 31	2019 performance period ends
2020	January 1	2020 performance period begins
	March 31	Deadline to submit 2019 performance data
	Spring	2018 payment adjustments implemented (+/- 5 percent)
	Fall	CMS feedback provided to clinicians for 2019 performance data

ASTRO Education

External Resources

QCDR 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.

2018 MIPS Many radiation oncologists will participate in MIPS in 2018. Medicare will adjust payments positively or negatively based on Quality, Promoting Interoperability, Improvement Activities and Cost performance categories.

2017 MIPS A majority of radiation oncologists were expected to participate in MIPS in 2017. Medicare will adjust payments positively or negatively based on Quality, Advancing Care information and Improvement Activities in 2019.

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.

Measures 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.

2019 QPP Final Rule Summary

On Thursday, November 1, 2018, CMS issued the 2019 Quality Payment Program (QPP) final rule that includes new eligibility requirements, category weights and reporting options.

Learn more

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.

Learn More

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