Many family physicians across the country are busy taking care of patients while simultaneously working to understand the regulations controlling CMS' new Quality Payment Program (QPP)(qpp.cms.gov).They should know that the agency itself has been under some scrutiny to produce a workable program.
Here's the deal. Midway through 2016, HHS' Office of the Inspector General (OIG) -- recognizing both the complexity of the QPP and the time constraints CMS was under to launch the program -- conducted an early implementation review of the agency's management of the QPP and released, in December 2016, a report of its findings.(oig.hhs.gov)
It's important to remember that CMS' QPP resulted from enactment of the Medicare Access and CHIP Reauthorization Act of 2015. That law's focus on quality and value drove the development of the two QPP tracks available to physicians -- the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (Advanced APMs).
Publication of the QPP final regulation didn't occur until October 2016, and the first performance year began shortly thereafter, on Jan. 1, 2017.
- The HHS Office of the Inspector General conducted an early review of CMS' implementation of the Quality Payment Program (QPP).
- The report highlighted two key findings that, if not address in a timely manner, could derail the program's success.
- Authors said CMS must provide appropriate help and technical assistance to get physicians ready to participate in the QPP, and it must create back-end IT systems to support work involved in data reporting, scoring and payment adjustment.
The report highlights two key findings that, if not addressed in a timely manner, could derail the program's success. Authors said CMS must
- provide appropriate help and technical assistance to get physicians ready to participate in the QPP, and
- create back-end health IT systems to support work involved in data reporting, scoring and payment adjustment.
Regarding the first point, the report's authors stressed the importance of assisting solo, small-practice and rural physicians and noted that if sufficient support is not made available, physicians will struggle to meet the reporting requirements.
The authors further noted that Medicare clinicians must first understand the QPP if they are to take advantage of the 2017 transition year designed to help physicians familiarize themselves with all the details of the program.
Physicians will then be equipped to pick the QPP participation option that best fits their medical practice and use QPP performance feedback -- again, during the no-foul transition year -- to make practice improvements aimed at enhancing the health care delivered to Medicare patients.
However, without needed course correction, "Frustrated providers may even opt not to participate in the QPP despite the payment penalty, limiting the program's ability to meet its goal," said the report.
Concerning the second bullet, on building and testing "back-end health IT systems," the authors noted that this task would require "significant and sustained effort" during the next year. Furthermore, they added, "If the complex systems underlying the QPP are not operational on schedule, the program will struggle to meet its goal of improving value and quality."
The health IT component is crucial, said the authors, because clinicians need to be able to report QPP data to CMS accurately and as easily as possible so the agency can then
- validate the data and calculate final MIPS scores,
- provide performance feedback to participants, and
- adjust Medicare Part B payments based on physicians' QPP participation.
All of these concerns likely will resonate with family physicians immersed in this transition, as they have with the AAFP, which has worked tirelessly for many months to provide resources and tools to help members both understand and do well in the future world of the QPP.
Methodology, Stakeholder Concerns
To facilitate its review of QPP implementation, the OIG interviewed CMS staff between June and November 2016 and reviewed both internal CMS documents and publicly available information.
The report's authors conducted a qualitative analysis to pinpoint key milestones, priorities and challenges related to implementation of the program. They noted that early on, "CMS staff decided that clinicians' acceptance of the QPP, and readiness to participate in it, would be the most critical factor to ensuring the program's success."
The report includes a section about stakeholder concerns and notes that alarms were raised early on by many, including Congress, professional associations and individual physicians. "CMS received over 4,000 comments on the proposed rule for QPP published in May 2016 and has continued to receive feedback after issuing the final rule in October 2016," noted the authors.
Include the AAFP among those organizations recommending extensive suggestions to CMS.
Among other things, stakeholders questioned whether the program was too burdensome financially and otherwise to allow solo, small and rural practices to participate. Commenters also expressed concern about the complexity of the program, the applicability and validity of specific MIPS measures, and the paucity of Advanced APM opportunities currently available.
Authors concluded that as of December 2016, CMS had made significant progress toward implementing the QPP. For instance, the agency had
- finalized key policies to implement the QPP, including issuing final regulations and identifying Medicare models that qualify as Advanced APMs for the first performance period,
- initiated engagement and outreach activities to physicians,
- launched a public-facing website with key program details, and
- awarded multiple contracts related to the provision of technical assistance and training for physicians.
The authors noted that if the QPP is to succeed, CMS cannot slow down its work; rather, the agency must expand its efforts to provide technical assistance to physicians, issue subregulatory guidance, award key contracts and oversee that work, and complete the development of backend health IT systems critical to supporting QPP operations.
In the "still to come" category, authors noted CMS plans in 2017 to
- provide physicians with information about their likelihood of meeting the qualifying APM participant threshold,
- increase Advanced APM opportunities and
- expand physician adoption of the new care delivery models.
In addition, "CMS must monitor the interplay of MIPS and Advanced APM financial rewards to identify any unintended consequences that would affect clinician participation," said the authors.
"As CMS gains more experience with clinician participation in the two QPP tracks and how payment adjustments are distributed, it will need to identify and address any competing incentives that would impede the program's ability to meet its goals," they added.
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