From: Hooper Lundy & Bookman – 10/18/16
On Friday, October 14, the Centers for Medicare and Medicaid Services (CMS) released the much anticipated Final Rule with comment period implementing the Medicare Access and CHIP Reauthorization Act (MACRA).
The Final Rule establishes a new program, the Quality Payment Program (QPP) with two tracks for physicians and other eligible clinicians being paid under Medicare fee-for-service. The first performance year for both tracks of the QPP will be 2017, for payment adjustments in 2019. The Final Rule provides further flexibilities from the proposed rule in order to help clinicians transition into the new payment system.
For the first year of the program, as determined in statute, eligible clinicians will include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. In response to concerns from stakeholders and small and solo practices, in the Final Rule CMS has eased the low-volume threshold for being exempt from the QPP as an eligible clinician with:
- less than or equal to $30,000 in Medicare Part B allowed charges, or
- less than or equal to 100 Medicare patients.
CMS estimates that this change to the low-volume threshold will result in approximately 32 percent of clinicians being exempt in 2017.
Transition Year – 2017
CMS refers to the first performance year, 2017, as a transition year, providing choices to eligible clinicians to participate in ways appropriate for their practice. The Pick Your Pace provision offers a four ways of participating in 2017 to avoid a negative payment adjustment. Non-reporting in 2017 will lead to an automatic negative adjustment of 4 percent in 2019.
Option 1: Test the program. By reporting one measure each in the quality and improvement activity categories or reporting the measures in the advancing care information category, clinicians can avoid a negative adjustment in 2019.
Option 2: Partially report. By reporting one measure in each performance category for a full 90 days in 2017, clinicians can avoid a negative adjustment and have the opportunity to possibly receive a small positive adjustment in 2019.
Option 3: Fully report. By reporting fully for 90 days to a full year, a clinician can earn a moderate positive payment adjustment and may be eligible for additional payment adjustments as exceptional performers.
Option 4: Participate in an Advanced Alternative Payment Model (AAPM). Those receiving 25% of Medicare payments or seeing 20% of Medicare patients through an AAPM in 2017, can earn a 5% incentive payment in 2019.