Quality-based Medicare payment is far from a new concept. However, the Quality Payment Program (QPP), created by the Medicare Access and CHIP Reauthorization Act (MACRA), introduces a new vocabulary, complex requirements and fast-approaching deadlines. Physicians have little time left to successfully navigate the program and avoid penalties for 2017.
A recent survey by the American Medical Association (AMA) found that nearly one-fifth of physicians had not yet started preparing for the Merit-based Incentive Payment System (MIPS), the performance track impacting most physicians under the QPP. For practices that intend to begin 90 days of reporting at or near the October 2 deadline for 2017 MIPS participation, there will be little room for error to avoid a penalty. If your practice won’t be able to complete 90 days of reporting, you can still avoid a penalty by participating in one patient, one measure, no penalty through Pick Your Pace. Either way, now is the perfect time to take stock of your readiness.
Physicians who are able, should take the following steps before October 2 to be ready for the final 90–day reporting period under MIPS. Action plans can help you determine the best path forward for your practice and help you manage the implementation over time. You and members of your practice can should consider using available resource tools to track your progress based on individualized dates and CMS deadlines to ensure all required MIPS components are adequately met. Action plans should include the following:
1. Get up-to-speed on performance categories. Three categories will be considered for MIPS: Quality, Advancing Care Information (ACI) and Improvement Activities (IA). You don’t have to participate in all three; instead, select the measures that apply to your practice.
2. Review your data. The Centers for Medicare and Medicaid Services (CMS) will provide Quality and Resource Use Reports (QRURs) and feedback reports to physicians who have participated in the Physician Quality Reporting System (PQRS) and Value Based Modifier (VBM) to avoid payment penalties. Both have been rolled into MIPS.
3. Pick your pace. Physicians have a choice of three participation tracks in 2017: minimum, partial and full.
4. Pick your measures. Full participation in MIPS requires you to submit measures on the Quality, ACI and IA components.
5. Meet with your clinician team. Review measure selection and discuss performance goals with your clinical team and administrative staff.
6. Decide to report as an individual or a group. Physicians can submit MIPS data as an individual or as a group under the group practice reporting option.
I know not all physicians or practices can adhere to the October 2 deadline and will need to utilize one patient, one measure, no penalty, but I urge my fellow physicians who have not yet begun their MIPS work to get started today in a manner that works for their individual practice.
David O. Barbe is president, American Medical Association.
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