As part of the continuing transition toward a physician payment system based more on quality than quantity, the Centers for Medicare & Medicaid Services (“CMS”) recently released a draft Quality Measure Development Plan (the “Plan”). The Plan is authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”), which mandated that CMS post a draft plan for the development of quality measures by January 1, 2016. The Plan explains how CMS will support the transition to the new Merit-Based Incentive Payment System (“MIPS”) and Alternative Payment Models (“APMs”).
Under MIPS, a single payment adjustment will be applied to physician payments beginning in 2019. The payment adjustment will be based on four categories: quality, resource use, clinical practice improvement and meaningful use of electronic health records technology. According to CMS:
“The [Plan] builds on the existing set of clinician quality measures used in current CMS programs, prioritizing the development of outcome measures and measures that are relevant for specialty providers. CMS will expand and enhance existing measures to promote alignment and harmonization, while concurrently developing new (de novo) measures to fill measure and performance gap areas.”
The Plan establishes a process for the annual solicitation, validation and approval of quality measures that will be utilized in the MIPS through an annual “Call for Measure.” CMS will then establish an annual list of MIPS quality measures through the rule-making process.
MACRA phases out three existing clinician reporting and incentive programs: the Physician Quality Reporting System, the Value-based Payment Modifier, and the Meaningful Use Electronic Health Record Incentive Program. The quality measures utilized in these programs will form the initial foundation for the Plan. The Plan focuses on gaps in these programs and provides recommendations to fill them.
Providers who participate in APMs may opt out of MIPS. The APM quality measures must be comparable to the measures used in MIPS.
The draft Plan is subject to public comment until March 1, 2016. The final Plan will be posted by CMS on or before May 1, 2016.