Late Thursday, CMS Acting Administrator Andy Slavitt previewed how CMS will treat the 2017 performance period under MACRA.
His blog post highlighted some significant shifts in the original MACRA implementation plan. The shifts give clinicians more flexibility, taking a “Pick Your Pace” approach to the quality payment program.
Clinicians that provide any data in the three Composite Performance Score (CPS) categories that require reporting (the Resource Use category is calculated by CMS using claims data) will be exempt from any penalties in 2019, the first payment period under MACRA, and may be eligible for a small bonus. Only those who do not report any data would face payment reductions.
CMS outlines three options for MIPS performance reporting in 2017.
- Test the Quality Payment Program.This option allows a practice to test its capability for reporting data. As long as some form of data is reported electronically at some point in 2017 they will avoid the penalty. The goal is to ensure a practice’s electronic system is functioning properly and can handle broader reporting in future years.
- Report for Part of the Calendar Year. Under the second alternative Slavitt described, a practice must report performance in all three CPS categories but can do so starting after January 1. According to the CMS blog, this could qualify a clinician for a “small” bonus in 2019.
- Report for the Full Calendar Year.This “ready, set, go” approach requires practices to report for the full calendar year in all three categories. These clinicians would be eligible for a “modest” bonus in 2019.
Slavitt notes that clinicians can still participate in the Alternative Payment Model (APM) track as described in the proposed rule, provided they meet eligibility requirements (receiving at least 20% of their revenue or treating at least 25% of their caseload through a CMS-approved Advanced Alternative Payment Model (APM).
CMS’ three options reflect a fine balance between encouraging practices to continue moving toward value-based payment and meeting clinicians where they are on this journey. As a result, in part, of going through the transformation process, many of NCQA’s recognized PCMHs will be ready for full reporting on January 1. We commend CMS for maintaining this option and expect that our practices will be well-positioned to realize a bonus in 2019.
The changes provide additional time to help other clinicians prepare to make MACRA work. But the move will only succeed if CMS and other federal policymakers remain committed to full implementation of the reporting requirements in 2018. Any indication that this time frame could slip further will discourage the work needed to get all practices ready. NCQA looks forward to serving as a source of objective, evidence-based guidance for all stakeholders during this important transition.
Amy Maciejowski is a Program Manager for State Affairs at NCQA. She supports NCQA’s work with state legislators and regulators. Amy holds a master’s degree in Political Communications from American University.