We are now well over halfway through 2017, the initial year of the new Quality Payment Program (QPP) mandated by MACRA. Accordingly, I thought it might be useful to revisit the topic of the QPP and MIPS (Merit-based Incentive Payment System) for purposes of emphasizing the key steps surgeons should take if they want to potentially see an increase in their Medicare physician payment in 2019 based on their performance in 2017. At the same time, I also want to make sure that all surgeons understand the ease with which they can avoid a payment penalty.
First, I want to assure all who have yet to take any action that there is still more than adequate time to do so. You absolutely can still compete for a positive update, or at a minimum, avoid a penalty. Further, it is so easy to avoid a penalty that no surgeon should be resigned to accepting a penalty without having a look at the minimal reporting requirements necessary to avoid it.
Dr. Patrick V. Bailey
One of the resources available on the ACS’ QPP website is an algorhythm intended to simplify surgeons’ decision making at their initial starting point. It is reproduced below:
1. Determine if all of your MIPS data will be reported by your institution or group via a Group Reporting option (GPRO).
a. If “YES,” you are done.
b. If “NO,” move to number 2.
2. Has CMS notified you that you are exempt from participating in MIPS due to the low-volume threshold?
a. If “YES,” you are done.
b. If “NO,” move to number 3.
3. If you want to compete for positive updates in your Medicare payment rates in 2019 (based on 2017 reporting), read the ACS Quality Payment Program Manual, watch the videos, and develop your plan.
4. If your goal is simply to avoid a penalty, CMS only requires data be reported for one of the following:
a. Required Base Score measures for your EHR (now known as Advancing Care Information) OR
b. One Improvement Activity for 90 days (report by attestation) OR
c. One Quality Measure on one patient (report by registry, QCDR, EHR, or claims)
Note: One is NOT required to have a certified EHR to avoid a penalty for 2017
5. If you did not report PQRS data and did not participate in the electronic health record meaningful use program in 2016 and have no intention of participating in MIPS in 2017:
a. Your lack of participation in 2016 programs will lead to a 10% negative payment adjustment in 2018.
b. Your lack of participation in MIPS in 2017 will lead to a 4% negative payment adjustment in 2019.
Note: This option is not recommended, as in future years the annual cuts will gradually increase to 9%.
MIPS is set up as a tournament model. In other words, “Losers” pay for “Winners.” Please do not put your money in someone else’s pocket. The ACS strongly encourages all Fellows to, at the minimum, participate at the level sufficient to avoid a penalty in 2017 and, thus, not serve as the “pay for” for another provider.
If you are not exempt from MIPS and therefore, one whose performance will be assessed in 2017, you still have plenty of time to start the process of reporting enough data to compete for a positive update. On the other hand, if your goal is simply to avoid a penalty in 2019, (based on your performance in 2017), you should take the few simple steps necessary to preclude such as outlined above.
We believe the QPP website, (www.facs.org/qpp), is an excellent resource for surgeons. It was designed to facilitate participation by those surgeons who must report for MIPS. As always, ACS staff are also available to answer your questions by phone or via e-mail: quality@facs.org.
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, DC.