Tuesday Mar 28, 2017
Pick-Your-Pace Program Can Help FPs Prepare for 2018
Spring has arrived!
As I have shared in previous years, this is my favorite time of year -- largely due to the fact that baseball season is here, and baseball season means longer days and warmer temperatures. For those not following closely, Opening Day is less than a week away.
Opening Day has to be the single most optimistic day of the year. It is the one day that every team has a chance to win the World Series, the crowds are big and loud, and everyone is pulling for the hometown team. On Opening Day, there are 30 teams who all believe that "this is their year," and they will compete for six months to be World Series Champions.
Reality slowly sets in during the summer, but nothing can beat the enthusiasm of Opening Day.
Speaking of enthusiasm! (levity my friends), I thought it would be a good time to discuss the Medicare Access and CHIP Reauthorization Act (MACRA) and share some new resources the AAFP has produced to assist you and your practice. As you know from a previous post, 2017 is the initial performance period of the MACRA Quality Payment Program.
Remember, if you engage in QPP at any level during the 2017 performance period, you will not receive a negative payment adjustment in 2019.
If you are a Medicare participating family physician, you are an eligible clinician (EC) for the purposes of participation in MACRA. As an EC, you will participate in one of the two MACRA QPP pathways -- the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Model (Advanced APM). Many family physicians will pursue participation in an Advanced APM, but a large number will initially participate in the MIPS pathway. If you take no action, you will be included in the MIPS cohort for the performance period.
There are three exemptions for Medicare participating physicians:
- Low Volume Threshold -- If your Medicare Part B allowable charges are less than $30,000 a year or you do not provide care to more than 100 Medicare Part B fee-for-service patients in a year, you are exempt from participation in the QPP. However, if your Medicare allowable charges exceed $30,000 a year and you provide care to more than 100 Medicare fee-for-service patients a year, you are part of MIPS.
- Initial Medicare Participation Year -- If 2017 is your first year as a Medicare participating physician, then you are exempt from participation in the MIPS program.
- Advanced APM -- If you are part of an Advanced APM, you are exempt from the MIPS program.
Step 1: Don't Panic
There are more than 900,000 physicians and other health care professionals participating in the Medicare program. Your current capabilities likely are far ahead of many of these ECs. Remember, practice transformation is a journey not a destination, and you should not try to master MIPS or an APM in a weekend. Take your time and be thoughtful, but diligent in your approach. I encourage you to think of the MIPS program as four functions -- not a comprehensive regulation. You likely are already doing these four things in your practice, so you are farther along than you may think. If you are not engaged in these activities, it's OK because you have time.
In the simplest terms, these are the four functions you need to prepare for:
- report quality;
- use an electronic health record (EHR);
- become a medical home or engage in performance improvement activities; and
- understand the resource use (cost) of your patients.
The AAFP has two great resources: Making Sense of MACRA and MACRAnyms that can assist you in this step.
Step 2: Reflect
I would encourage you to reflect on your current capabilities and compare that to the four functions outlined above.
- Do you currently report quality to Medicare, Medicaid, or a private insurer?
- Do you have a certified EHR?
- Have you reviewed your Quality and Resource Use Report (QRUR)?
- What skill sets do you currently have in your practice?
After you complete this inventory, itemize and prioritize your strengths, weaknesses, and gaps. Then prepare a plan to prepare for 2018, not 2017. Remember, if you engage at any level in 2017 you will avoid a negative payment adjustment in 2019.
Step 3: Evaluate and Develop a Plan with a Timeline
As we move towards advanced delivery models and value-based payments, it is important for you to truly understand your patient population. This will assist you in developing a quality and performance improvement strategy, which will better position you for success in MACRA and other value-based payment programs. A few items for you to think about:
- Who are your patients?
- What are the most common health conditions among your patient panel?
- What are the most common services provided in your practice?
- Who are your payers?
It may seem trivial, but taking some time to reflect on your patients and the capabilities of your practice will assist you moving forward. The AAFP's Making Sense of MACRA: Understanding Your MACRA Pathway is a good resource to consult. After you have evaluated your patients, practice capabilities, and the composition of your payers; develop a plan of action with a timeline. Approach your plan and execution timeline from the perspective of, "Where do we want to be on Jan. 1, 2018," not, "Where are we today?"
Step 4: GO!
I know you may not want to, but the best thing you can do is get started. The Pick-Your-Pace program is an excellent opportunity to engage in the QPP program and avoid negative payments in 2019. The AAFP has extensive resources on the Pick-Your-Pace program. CMS also has extensive QPP resources www.qpp.cms.gov for physicians. These are the descriptions from our MACRAReady resources on the four options available under Pick Your Pace:
- Test -- Submit data for one quality measure, or one improvement activity, or the four required advancing care information (ACI) measures and avoid a negative payment adjustment. Read a practice scenario for the test option.
- Partial Participation -- Submit at least 90 days of data for more than one quality measure, OR more than one improvement activity, OR more than the four required ACI measures and avoid a negative payment adjustment. Partial participation also allows ECs to possibly receive a small positive payment adjustment. Read a practice scenario for the partial participation option.
- Full Participation -- Submit at least 90 days of data for all required quality measures, and all required improvement activities, and more than the four required ACI measures to avoid a negative payment adjustment. Full participation also allows ECs to possibly receive a moderate positive payment adjustment. Read a practice scenario for the full participation option.
- Advanced Alternative Payment Model -- Eligible clinicians will receive a 5 percent bonus if they receive 25 percent of Medicare Part B payments, or see 20 percent of patients through an Advanced APM.
Think of 2017 as a dress rehearsal. The Pick-Your-Pace program provides an opportunity to test your capabilities and prepare for 2018 when the payment adjustments become real.
In my next post, which will publish on Tuesday, April 11, I will be addressing many of the comments you have submitted in response to this blog during the past few months. Many of you have submitted thoughtful comments, questions and suggestions on the various issues I have covered during the past three months, and I look forward to answering your questions and addressing your concerns. Your comments inform our thinking and influence our work. I look forward to sharing some perspective with you.
Posted at 07:00AM Mar 28, 2017