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The Quality Payment Program Final Rule has landed, and at a whopping 2,398 pages, it contains a lot of information. The healthcare data experts at ScanSTAT Technologies have summarized the “seven circumstances” of the rule specifically related to MIPS which you need to know to prepare for 2017.

What is the Quality Payment Program?

On October 14th, 2016, the Center for Medicare and Medicaid Services (CMS) announced the Final Rule of the Quality Payment Program (QPP). The QPP breaks down into two pathways, Merit-Based Incentive Payment Systems (MIPS) and Alternative Payment Models (APMs). This Quality Payment Program serves as a means to measure and reward those clinicians who emphasize and deliver quality care. Because only some clinicians are eligible for APM, CMS has requested all Eligible Clinicians report MIPS measures in 2017.

Who does MIPS apply to?

The Merit-Based Incentive Payment Systems (MIPS) program applies to those defined as an Eligible Clinician (EC) under Medicare who bills more than $30,000 a year in Medicare or provides care for more than 100 Medicare patients. In 2017, approximately 600,000+ Eligible Clinicians qualify for participation in MIPS. This includes MDs, DOs, PAs, NPs, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists. Those clinicians who are newly enrolled in Medicare are not required to participate in 2017.

When does MIPS begin?

The data collection period for MIPS will begin January 1st, 2017 — right around the corner! Data collected from 2017 will be reported and reviewed in 2018, ultimately determining an Eligible Clinician’s rate of reimbursement for the 2019 calendar year.

Where will MIPS be implemented?

The Quality Payment Program, which includes MIPS, is designed and enforced by CMS. However, “when CMS institutes, commercial payers follow suit.” The Final Rule includes provisions for commercial payers to submit programs as part of the Alternative Payment Model (APM) program. While this rule is specific to Medicare reimbursement, healthcare providers can expect that reimbursement across the board will be impacted by the QPP.

By What Means will clinicians be measured?

The expectations for data collection and reporting for 2017 include:MIPS contains four performance categories related to quality and cost of patient care. 2017 is deemed a “transition year,” and ECs will be measured across three categories: Quality, Advancing Care Information and Improvement Activities. The “transition” period also allows ECs to “pick a pace of participation” in order to acquaint themselves with the new program.

The expectations for data collection and reporting for 2017 include:

  • Quality – 60% of 2017 Reporting Weight
    • 2017 Individual Reporting Requirement:
    • Report up to 6 quality measures including an outcome measure for a minimum of 90 days
  • Advancing Care Information – 25% of 2017 Reporting Weight
    • 2017 Individual Reporting Requirement:
      • Security Risk Analysis
      • ePrescribing
      • Provide Patient Access
      • Send Summary of Care
      • Request / Accept Summary of Care
    • Fulfill the following measures for a minimum of 90 days
    • Up to 9 measures can be submitted for a minimum of 90 days for additional credit
  • Improvement Activities – 15% of 2017 Reporting Weight
    • 2017 Individual Reporting Requirement:
    • Attest the EC completed four improvement activities for a minimum of 90 days

In What Way will clinicians be reimbursed?

MIPS is designed to be a budget-neutral program. ECs will be scored and ranked following the end of a reporting year. Those who perform better than an established threshold will receive a positive payment adjustment, while those who perform below the threshold will receive a negative payment adjustment. Those ECs who perform at the threshold will receive a neutral payment adjustment. The Final Rule does allow for exceptional performers to receive an additional positive payment adjustment if they meet or exceed a 70 threshold final score for 2017. MIPS begins with a +/-4% adjustment, and currently grows to +/-9% over a period of years.

  • Collection for 2017 performance data must begin between January 1st and October 2nd 2017 in order to collect 90 days of data
  • Performance data for 2017 must be reported by March 31st, 2018
  • Payment adjustments based on 2017 data will begin on January 1st, 2019

For 2017 data collection, an EC has the following options for participation and 2019 calendar year payment adjustment:

  • Don’t participate: -4% payment adjustment; Submit no data for 2017 reporting
  • Test: Neutral payment adjustment; Submit a minimal amount (one measure or more) of data for 2017 reporting
  • Partial: Neutral or Small positive payment adjustment; Submit 90 days of data for 2017 reporting
  • Full: Moderate positive payment adjustment; Submit a full year of data for 2017 reporting

Why are we implementing the Quality Payment Program?

Put simply, our former Fee-for-Service system drove up costs and did not guarantee quality care. By creating and enforcing a program which measures quality outcomes, CMS will reward clinicians who demonstrate providing quality care for patients, while ultimately monitoring and ensuring appropriate cost data. In time, this currently budget-neutral program should evolve to lower per capita healthcare spending, while at the same time improve the outcomes of our patient population. While only time will tell if the QPP is effective, one thing if for sure: MIPS is here and quality-based reimbursement can no longer be ignored.

Stay tuned! ScanSTAT will continue to research and share details about the Quality Payment Program. We expect to publish more information about this important topic soon.

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