OP-ED

Plans For the Quality Payment Program in 2017: Pick Your Track

Screen Shot 2016-07-07 at 2.30.28 PMAs the baby boom generation ages, 10,000 people enter the Medicare program each day. Facing that demand, it is essential that Medicare continues to support physicians in delivering high-quality patient care. This includes increasing its focus on patient outcomes and reducing the obstacles that make it harder for physicians to practice good care.

The bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) offers the opportunity to advance these goals and put Medicare on surer footing. Among other policies, it repeals the Sustainable Growth Rate formula and its annual payment cliffs, streamlines the existing patchwork of Medicare reporting programs, and provides opportunities for physicians and other clinicians to earn more by focusing on quality patient care. We are referring to these provisions of MACRA collectively as the Quality Payment Program.

We received feedback on our April proposal for implementing the Quality Payment Program, both in writing and as we talked to thousands of physicians and other clinicians across the country. Universally, the clinician community wants a system that begins and ends with what’s right for the patient. We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

But, with the Quality Payment Program set to begin on January 1, 2017, we wanted to share our plans for the timing of reporting for the first year of the program. In recognition of the wide diversity of physician practices, we intend for the Quality Payment Program to allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017. During 2017, eligible physicians and other clinicians will have multiple options for participation. Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019. These options and other supporting details will be described fully in the final rule.

First Option: Test the Quality Payment Program.

With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment. 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.

Second Option: Participate for part of the calendar year.

You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than January 1, 2017 and your practice could still qualify for a small positive payment adjustment. For example, if you submit information for part of the calendar year for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a small positive payment adjustment. You could select from the list of quality measures and improvement activities available under the Quality Payment Program.

Third Option: Participate for the full calendar year.

For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on January 1, 2017. For example, 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. We’ve seen physician practices of all sizes successfully submit a full year’s quality data, and expect many will be ready to do so.

Fourth Option: Participate in an Advanced Alternative Payment Model in 2017.

Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.

However, you choose to participate in 2017, we will have resources available to assist you and walk you through what needs to be done. And however you choose to participate, your feedback will be invaluable to building this program for the long term to achieve outcomes that matter to your patients.

We appreciate the sincere and constructive participation in the feedback process to date and look forward to advancing step-by-step in that same spirit. We look forward to releasing the final details about the program this fall. Most importantly, we look forward to further engagement with physicians and other clinicians toward our shared goal of the highest quality of care and best outcomes for patients.

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Pesto SaucepjnelsonHans Duvefelt MDanish_kokajamesepurcell Recent comment authors
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Pesto Sauce
Member
Pesto Sauce

Respectfully, I’m sensing “Hmm, would you like a crap sandwich, or a sandwich of crap?” Physicians and “providers” are completely exhausted and done done done with EHR and government mandates that have us spinning around and then lead us nowhere. You (plural, encompassing government appointees and politicians) as bureaucrats do not see the impact your Kafkaesque-policies have had on the destruction of ambulatory primary care. You do not implement policy out of a sound knowledge on the sociology of medicine. It’s all about the favors that have been owed, and the pork that needs to be doled out. To suggest… Read more »

pjnelson
Member
pjnelson

Andy, For a Primary Physician, the long-standing, worsening reimbursement for Basic Healthcare Needs by CMS has led to a supremely under-capitalized segment of the healthcare industry: Primary Healthcare. The remote possibility of a 5% “bonus” is an insult. Furthermore, you haven’t commented on the accuracy of assigning a Medicare citizen’s PCP status. So, how can a Primary Physician learn anything from CMS when the data is likely to be seriously in error, especially a penalty rather than a bonus? The real issue facing the reform of our nation’s healthcare industry is the burgeoning increase in Medicare eligible citizens in the… Read more »

Hans Duvefelt MD
Member

I agree with the previous comments, and especially with the notion about a control group. As clinicians, we don’t usually change our clinical behavior just because of “expert opinions”, and that is what you are basing your behavior on. Our stance is “show us the data” that proves this new drug or this new blood pressure target causes improved outcomes and/or lower cost to our patients. I think it is obvious that clinicians are suspicious of any imposed change in how we do things if there is no data to support it, or at least the promise that there will… Read more »

anish_koka
Editor

I realize that the option to delay any reporting is meant to mollify the angry physician, but that isn’t what physicians were asking for. There was a time where idealistic young physicians (that would have been me) lapped up the reasonable sounding Obama/Andy speak. Who needs details? The big picture is what matters. Let’s give good quality care to our patients, and get paid more if we do, less if we don’t. Unfortunately, it is not enough to say the right things – you have to be able to implement. The current administration is very long on vision, and remarkably… Read more »

meltoots
Member
meltoots

Anish, to quote the movie Step Brothers…”are we becoming best friends?”. You are right on the mark with this… recently Dartmouth has had to eat their “ACOs are great” shoe. They dropped out of the program because…wait for it….It costs money to setup and run AND they claim that they are so low cost already, that they cannot squeeze another drop of savings out, so they are somehow then penalized by CMS. Classic. Now they say, maybe “Sounds good” doesn’t work, that all these ACOs/APMs/fancy data entry heavy programs DON’T save money, even though they sound pretty good. Further, they… Read more »

jamesepurcell
Member

As someone who has never used an EMR, nor seen much less treated a patient, it is difficult for me to comment intelligently. Be that as it may, I look for themes or threads in things like Andy’s blog and the comments, and similar blogs and comments in the past. There seems to be significant physician disgust with EMRs of today which is exacerbated by what many of the commenters portray as largely useless and time consuming reporting, all for say 5% bonuses? I know I wouldn’t bust my back for 5%. I might, however, bust my back IF I… Read more »

Niran Al-Agba
Member

You are heading in the proper direction regarding the new option for flexibility. I agree, of course, with the other posters below. We need a control group aka “leave us alone” in this study of the Quality Payment Program. When there are multiple options for a new system, it should be compared to what we already have at this moment before simply assuming it is the correct path to take because it is new. I, for one, am happily volunteering to be part of the control group of physicians. If, after three years, my group is costing more money overall,… Read more »

LeoHolmMD
Member
LeoHolmMD

Agree completely with the “leave us alone” path proposed here. At the very least, you will need control data to determine if all this quality interference is actually harming people instead of helping. There is already evidence that small indy practices have reduced hospitalizations, improved access and higher satisfaction. Been doing it without quality mongering programs.

Greg Fulton
Member
Greg Fulton

Welcome news overall, though realistically these are three new options, as A-APM has been on the table since the proposed rule. Also clear that potential relief for solo, rural, HRSA providers is embedded, meaning all practice types and sizes are offered the flexibility to level the playing field and make further good on earlier efforts to aid these provider types. Also looks like A-APMs won’t be expanded beyond the current six, but maybe we can hold out hope that the QP and partial QP thresholds may lessen to increase participation opportunity there, and no surprise the reporting options harken “back”… Read more »

meltoots
Member
meltoots

Pick your poison. Andy, with all due respect and I do think I would like you as a person, I think this we are going to beat you lightly this year and then club you with a bat next year and beyond is not going to fly. We do appreciate the one year reprieve, but full MACRA is a huge distraction to patient care, not to mention onerous, irrelevant, burdensome, expensive, etc etc. So to tell us to get used to the beatings for a bit but expect a full on smack down in a year means that you heard… Read more »