On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) issued proposed regulations (Proposed Regs.) as a first step in the implementation of the Quality Payment Program (QPP) provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In response to public comments regarding the Proposed Regs., CMS announced on September 8, 2016 (QPP Notice) that the final QPP regulations which CMS intends to issue in November, 2016 will allow physicians to “pick their pace” of QPP participation for the first MACRA performance period beginning on January 1, 2017.

The QPP and Pay-for-Performance. As described in a prior blog post, MACRA established the QPP as a mechanism to reward Medicare participating physicians for the provision of high quality care to Medicare beneficiaries. As such, the QPP ties reimbursement for Medicare-covered services to patient outcomes – in other words, the quality of Medicare patient care rather than the quantity of Medicare patient care. Specifically, the QPP repeals the Sustainable Growth Rate formula and its annual payment cliffs, streamlines the existing patchwork of Medicare reporting programs, and provides opportunities for physicians and other clinicians to earn more by focusing on quality patient care.

CMS’ September 8, 2016 Announcement. Although CMS has yet to issue the final QPP regulations (it intends to do so by November 1, 2016), the looming QPP start date of January 1, 2017 caused CMS to share its plans for the timing of reporting for the QPP’s first year in the QPP Notice. As described by Andy Slavitt, Acting Adminstrator of CMS, in the QPP Notice, “in recognition of the wide diversity of physician practices, we intend for the Quality Payment Program to allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017.”

QPP Implementation Options. According to the QPP Notice, providers will now have four options to comply with QPP including the use of alternative payment models as a substitute for QPP. The four options are:

  1. For providers not ready to implement MACRA:
    Participate with partial data
    Providers can avoid negative payment adjustments by submitting any data to the QPP; this includes data from after January 1, 2017. The simplest and most flexible of the options, this option ensures provider systems are working and providers are ready to fully participate in the coming years.
  2. For providers that need a little more time:
    Participate for less than a calendar year
    For providers not quite ready for full MACRA/QPP implementation, CMS offers the option to submit for a reduced number of days. Providers can begin submitting data later the January 1st start of the payment reform and still qualify for at least a small positive payment adjustment.
  3. For providers ready to collect and submit data:
    Participate for a full calendar year
    Providers ready for payment reform can start submitting to the QPP starting January 1st, 2017. The first performance period must fall on the start of MACRA for a slightly higher positive payment adjustment. CMS expects many practices of all sizes will be ready to comply with MACRA under this option.
  4. For providers wanting to avoid submitting quality data:
    Participate in an advanced alternative payment model

    Joining an Advanced Alternative Payment Model will qualify as participation in the QPP without having to report quality data. Examples of Advanced Alternative Payment models are Medicare Shared Savings Track 2 or 3 and Medicare Shared Savings ACO. To qualify for a 5% incentive payment in 2019, providers must receive “enough of [their] Medicare payments or see enough of [their] Medicare patients” through the model in 2017.

Provider Groups React. In response to the QPP Notice, several provider groups quickly released statements of support.

In a September 8, 2016 statement attributed to Andrew W. Gurman, M.D., the President of the American Medical Association (AMA), the AMA praised the QPP Notice by stating that it presents a “thoughtful and flexible approach.” In addition, the AMA said that the QPP Notice’s approach on MACRA implementation, “… better reflects the diversity of medical practices throughout the country.”

The American Hospital Association (AHA) also applauded CMS’ announcement. In a September 8, 2016 statement, Ashley Thompson, AHA’s senior vice president for public policy analysis and development, said, “We are pleased that CMS has responded to feedback asking for greater flexibility in meeting MACRA’s aggressive timeline and reporting requirements.”

Finally, in a September 8, 2016 statement attributed to Nitin S. Damle, MD, MS, FACP President, American College of Physicians (ACP), the ACP praised CMS’ plans, “… to implement changes to give physicians more options to participate in the Quality Payment Program in 2017 without being at risk of negative adjustments.”