Your Blueprint for Navigating the Quality Payment Program, created by The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)
Understand The QPP
The Quality Payment Program, created by The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), established a framework for a quality-based system and streamlined quality reporting programs into one system. Medicare payments are now stable as the flawed Sustainable Growth Rate formula is no longer in effect.
Physicians and advanced practice professionals (physician assistants, nurse practitioners, clinical nurse specialists) in both practice and hospital settings.
Clinicians must participate in one of two tracks to be eligible for Medicare payment incentives:
- Merit-Based Incentive Payment System (MIPS): Streamlines previous quality reporting programs (Physician Quality Reporting System, Value Modifier and Electronic Health Record Incentive Program) into one program.
- Advanced Alternative Payment Models (APMs): Open up new methods of paying providers under Medicare.
Understand the Performance Categories:
Rewards clinicians based on the quality of care delivered
40% of final score
Rewards clinicians for meaningful use of certified electronic health record technology
25% of final score
Rewards clinicians for participating in activities focused on improving care coordination, practice access, patient safety, population management, health equity and more
15% of final score
Rewards clinicians and groups based on the cost of care provided to Medicare beneficiaries
20% of final score
MIPS Value Pathways (MVPs)
MIPS Value Pathways (MVPs) are a subset of measures and activities. Established through rulemaking, MIPS participants can use MVPs to meet MIPS reporting requirements.
In the 2020 Medicare Physician Fee Schedule (PFS) Final Rule, CMS finalized its MVPs to begin with the 2021 performance period. However, in order to address stakeholder concerns about this timeline, and to account for the COVID-19 public health emergency, CMS will not be implementing MVPs as a reporting option for MIPS measures and activities during the 2021 performance period. Instead, CMS has released guiding principles and the establishment of MVP development criteria to support stakeholder collaboration in developing MVPs with CMS.
CMS also seeks to receive and evaluate MVP candidates beginning with the 2022 performance period, including the use of a standardized template.
Phases of Participation:
- Determine if Qualified Clinical Data Registry (QCDR) Quality reporting or another reporting mechanism is appropriate for you.
- Become familiar with the Quality measures most applicable to your practice and patient population.
- Determine if you are participating in an APM. If you are participating in certain APMs, you may only have to fulfill the Quality requirements of your model and not report any additional MIPS Quality data.
- Review a list of eligible Improvement Activities. Take note of which activities you may already be participating in and which activities you may want to engage in.
- Determine if you are in an APM, small practice or rural practice that may qualify for flexibility in this category.
- ACC’s PINNACLE Registry, Diabetes Collaborative Registry and quality improvement initiatives may be able to help you meet several Improvement Activities. Decide if the registries or initiatives are a good fit for your practice.
- 2015 certified electronic health record technology (CEHRT) is now required unless you qualify for a hardship exception. Review the EHR Contracting Guide and the Health IT Playbook to explore the purchase or upgrade of CEHRT to meet the MIPS objectives and measures.
- Engage a vendor of CEHRT who can assist you in preparing your EHR system and staff for MIPS reporting.
- Enroll in the PINNACLE Registry and qualify for a Public Health Registry Bonus Point on your total Promoting Interoperability performance category score.
- Determine how to manage variability in your episodes of care. The Cost category currently scores on episodes for procedures such as Elective Outpatient PCI, STEMI with PCI, and Revascularization for Lower Extremity Chronic Critical Limb Ischemia. Additional procedural and condition-based episodes will be implemented in future years.
- Review your previous Cost data when it becomes available as part of your MIPS feedback. Determine ways to improve the cost of care provided to your patients. If you are a “high cost” clinician or group, you may want to evaluate your highest cost services and/or patients and determine if there are ways to improve your management of these cases.
- Figure out who manages Cost data where you practice. Work with them to access and understand your performance.
Participants are exempt from MIPS if a certain threshold of their Medicare patients are treated or Part B payments are received as part of an Advanced APM. Advanced APMs are those models that meet the following requirements:
- Require participants to use certified electronic health record technology (CEHRT)
- Base payments on Quality measures comparable to those used in MIPS (Quality performance category)
- Is either a Medical Home Model expanded under the Center for Medicare and Medicare Innovation or requires participants to bear more than nominal financial risk