By Janette Jones, Senior Consultant for CAHPS Administration
In late 2016, the Centers for Medicare & Medicaid Services (CMS) released finalized regulations for implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. MACRA, which is in effect now, does a number of things. Namely, it serves as a new Quality Payment Program for Medicare Part B clinician reimbursement, ends the Sustainable Growth Rate formula and refocuses reimbursement on efforts to improve care delivery, engage patients and their caregivers, and enhance care coordination and population health management.
Under MACRA, clinicians have three options for reporting quality data to CMS: the Merit-based Incentive Payment System (MIPS), Advanced Alternate Payment Models (APMs) and CAHPS for MIPS. MIPS combines the Physician Quality Reporting System, Value Modifier Program and Electronic Health Record Incentive Program into a single reporting program. MIPS scoring considers four weighted performance categories:
- Quality (60%).
- Advancing care information (25%).
- Improvement activities (15%).
- Cost (calculated from adjudicated claims, no data submission required).
The MIPS performance period for 2017 began January 1 and closes December 31, 2017. During this first year of MIPS, eligible clinicians must submit at least 90 days worth of data to avoid a downward payment adjustment. Clinicians who aren’t yet collecting data have until October 2, 2017 to get started. All clinicians reporting for 2017 will have until March 31, 2018 to deliver performance data in order to avoid the downward adjustment. Clinicians will be able to submit as an individuals or as part of a group.
The Advanced APM path is designed for clinicians and groups implementing care models that go further and bear more risk in delivering high-quality, coordinated and efficient care. To qualify as an Advanced APM, care models must:
- Require participants to use certified EHR technology.
- Provide payment for covered professional services based on quality measures comparable to those used in the MIPS quality performance category.
- Either be a Medical Home Model expanded under CMS Innovation Center authority or require participating APM Entities to bear more than a nominal amount of financial risk for monetary losses.
To be considered part of an Advanced APM Entity, eligible clinicians must be on an APM Participation List on March 31, June 30 or August 31 of the performance reporting period. Otherwise, clinicians should prepare to engage MIPS methods, which include utilizing a Qualified Clinical Data Registry (QCDR) for performance reporting.
CAHPS for MIPS is another option available for reporting and follows the same process as CAHPS for the Physician Quality Reporting System – the reporting option it is replacing. It is not anticipated that the CAHPS for MIPS survey will be required for specific groups of clinicians in 2017 but will be available for all groups to select as a reporting measure. Clinicians and groups interested in participating in CAHPS for MIPS need to register for the program by the end of June 2017.
Bivarus is prepared to answer your questions and support you in meeting requirements for MIPS and Advanced APM reporting. We offer an approved QCDR as a flexible reporting option, as well as administration of CAHPS for MIPS for the 2017 performance year.