This month, we continue our discussion of the Quality Payment Program (QPP). Specifically, I write about a blog post from CMS Acting Administrator, Andy Slavitt, on Sept. 8, 2016. In that post Mr. Slavitt announced “plans for timing of reporting for the first year of the [quality payment] program” and stated that CMS “intend[s] for the Quality Payment Program to allow physicians to pick their pace of participation for the first performance period that begins Jan. 1, 2017.”
Though specific details are unknown at this time pending the release of the QPP final rule on or about Nov. 1, 2016, Mr. Slavitt’s post would seem to indicate that it will be possible for providers to avoid payment penalties and further that it should also be possible to receive a positive update in Medicare payment depending upon the level of one’s participation in the new program in 2017.
Options for Participation
Acting Administrator Slavitt’s post states, “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.”
Outlined below are those four options:
Option 1: Test the Quality Payment Program
With this option, one will be able to avoid a negative payment adjustment, “as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017.”
This option is designed to ensure preparation for broader participation in 2018. As with all types of regulation, the “devil is in the details” and specifically, what constitutes “some data” is not defined at this time. As mentioned above, we expect such details to be described fully in the final rule, but I believe surgeons have reason to be optimistic that all should be able to avoid penalties under the first year of the QPP.
Option 2: Participate for part of the calendar year
For providers who choose to submit data for the QPP for less than a full year, i.e., “a reduced number of days,” their performance period could begin sometime after Jan. 1, 2017, and their “practice could still qualify for a small positive payment adjustment.”
For surgeons who are already participating in the current PQRS (Physician Quality Reporting System) program via the American College of Surgeons’ Surgeon Specific Registry (SSR) or other certified registry, this option presents an opportunity to be rewarded for those efforts. To reiterate, details relative to the threshold of participation required for the positive adjustment will not be known until the final rule is released. However, it is entirely possible that many surgeons will be eligible for a positive update based upon what they are already doing or could easily begin doing in 2017.
Option 3: Participate for the full calendar year
Option three is for practices that are ready to fully participate in all four components of the QPP for the entire calendar year of 2017. Those practices that submit information for the entire year on quality, the use of electronic health record technology, and their practice’s improvement activities “could qualify for a modest positive payment adjustment.”
For those practices that have invested in electronic health record technology and are already reporting PQRS data, “gearing up” to participate for the full calendar year may not be an arduous endeavor. Once the final rule is released and specific details are known, they may find that their previous efforts toward preparation for the QPP puts it well within their capability to fully participate in 2017 and receive a positive payment adjustment.
Option 4: Participate in an Advanced Alternative Payment Model (APM)
“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 …” Mr. Slavitt stated.
As has been stated in previous editions of this column, for the first few years of the QPP we expect that most surgeons will participate in the QPP via the Merit-based Incentive Payment System (MIPS) pathway and not in APMs. However, the development of Advanced Alternative Payment Models widely applicable for surgeons is the object of significant and ongoing policy development efforts by the Division of Advocacy and Health Policy of the American College of Surgeons.
For those wishing to read Acting Administrator Slavitt’s post in its entirety, it may be found here:
Until next month.
Dr. Bailey is a pediatric surgeon, and Medical Director, Advocacy, for the Division of Advocacy and Health Policy in the ACS offices in Washington, D.C.