Last week, CMS head Andy Slavitt posted a blog on CMS’ website titled, “Plans for the Quality Payment Program in 2017: Pick Your Pace.” Written amid news reports and growing speculation of CMS’ plans to delay the start of the initial MACRA reporting period, Mr. Slavitt’s blog confirmed that the reporting period will start January 1, 2017, while also announcing CMS’ plans to create new “flexible” reporting options for providers in the final rule.
Four Options for 2017
Mr. Slavitt’s blog describes four options for providers to participate in MACRA’s Quality Payment Program (which is CMS’ name for MACRA’s MIPS and Advanced APMs payment tracks) in 2017.
The first option would allow providers to “test the quality payment program.” Under this option, providers would be exempt from 2019 MIPS adjustments (which are tied to the 2017 reporting period) as long as they “submit some data to the Quality Payment Program, including data from after January 1, 2017.” Mr. Slavitt noted this 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 would allow providers to submit MIPS data for “part of the calendar year” to avoid payment adjustments and potentially qualify for a “small positive payment adjustment.”
Under the third option, providers could submit MIPS performance data for the full-year reporting period, beginning January 1, 2017, to potentially qualify for a “modest positive payment adjustment.”
Lastly, the fourth option would offer providers an exclusion from the MIPS adjustments and a 5 percent incentive payment in 2019 for receiving a certain amount of payments through or seeing a certain percentage of patients under an Advanced Alternative Payment Model (APM) in 2017.
As noted by Mr. Slavitt, “choosing one of these options would ensure you do not receive a negative payment adjustment in 2019.” However, it’s important to note that we’ll still need to wait until CMS releases the final MACRA regulation to fully understand these four options, due to the lack of specifics included in the blog post. For instance, under the first option, we don’t know how CMS will define “some data.” And under the second option, we don’t know whether CMS will allow providers to submit data for any part-year reporting period or just certain part-year reporting periods, such as six months or 90 days. As always, the devil will be in the details.
Move Ahead with Preparations for January 1
Provider organizations, many who had been pushing CMS to delay the start of the reporting period six months to July 1, 2017, welcomed this announcement. From CMS’ perspective, it represents a compromise as they are moving ahead with the proposed January 1 start date for groups who are ready, while offering groups and solo practitioners who aren’t ready every opportunity to avoid the negative adjustments.
From a strategic perspective, physician groups would be wise to ignore this announcement and continue to prepare to report a full year of MIPS data for the 2017 reporting period. Granted, with this announcement, there will be a reduced pool of penalties from which to pay the MIPS incentives in year one; but there still will be some incentives (including the $500 million pool of extra incentives for exceptional performers). Performing well in MIPS in 2017 will also help position physician groups for success in subsequent years as the program’s financial impact increases.