Kudos to Andy Slavitt, Acting Administrator of CMS. At least he appears to have the individual physician in mind as he writes this CMS Blog regarding the MACRA program. He recognizes that, “the clinician community wants a system that begins and ends with what’s right for the patient.” He appears to believe that the Quality Payment Program portion of MACRA can address this issue and provide proper reimbursement to physicians and other clinical services providers without adding additional layers of time-consuming reporting requirements.
The first performance period for this Quality Payment Program is set to begin January 1, 2017. It is imperative, therefore, that physicians and other clinicians understand and choose their level of participation within the next three months in order to avoid “a negative payment adjustment in 2019,” otherwise known as a penalty. There are presently four options, or levels of participation, for providers to choose from, which are:
- The first is an entry level of participation which requires the provider to “submit some data to the Quality Payment Program, including data from after January 1, 2017.” Addressing the physician, Slavitt further states, “This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.”
- The second option allows for submitting quality measures for a portion of the year and that the first performance period could begin later than January 1, 2017. Slavitt further states that, “your practice could still qualify for a small positive payment adjustment.”
- The third option is for practices that are prepared and ready to participate for the full year as of January 1, 2017. Slavitt states, “if you submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a modest positive payment adjustment.”
- The fourth level of participation is “by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017.” This would allow the practice to “qualify for a 5 percent incentive paymentin 2019.”
The final rule for MACRA and the Quality Payment Program is due to be released November 1 of this year. This will allow two months - essentially 60 days - for physicians and practice administrators to select the pace of participation appropriate for their particular practice, summarized here:
PARTICIPATION LEVEL - EFFECT ON PAYMENT
0 - No participation - Practice is subject to a negative payment adjustment in 2019
1 - Minimal participation - Practice avoids the negative payment adjustment in 2019
2 - Partial year participation - Practice could receive a small positive payment adjustment in 2019
3 - Full year participation - Practice could receive a modest positive payment adjustment in 2019
4 - Join an AAPM program - Practice could receive a 5% payment increase incentive in 2019
The MACRA program is still one of the best kept secrets in healthcare as I indicated in this blog. The best kept secret has been how clinicians can get the information and education necessary to properly participate in the Quality Payment Program. The contracts for the MACRA Quality Improvement Direct Technical Assistance training programs still have yet to be awarded. They are due to be announced in November, just a couple of months before the program goes into effect, January 1, 2017.
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