Clinicians have until March 31 to submit 2017 performance data for the Quality Payment Program established after passage of Medicare Access and CHIP Reauthorization Act (MACRA). 2018 will require a full year of reporting, but with more clinicians exempt from the Merit-based Incentive Payment System (MIPS) and the program itself threatened with elimination, providers have become wary of making long-term changes.
To gain some insight into how providers handled the first year of the new QPP payment tracks, how clinicians have pushed into Advanced Alternative Payment Models (Advanced APMs) and whether more clinicians will be made exempt in the next CMS rule for QPP, HealthExec spoke with Beth Houck, MBA, the vice president of client services at value-based program compliance and analytics software company SA Ignite, at the HIMSS18 conference in Las Vegas.
HealthExec: What lessons did providers take from the limited QPP participation into 2017 to improve their performance in 2018?
Beth Houck, MBA: Many of our customers chose to participate as fully as possible in the QPP in 2017. We learned that those organizations that were only able to participate in a limited way, primarily chose this route in order to focus resources on establishing the infrastructure and process that would allow them to fully participate in 2018. Usually, this meant electronic health record (EHR) consolidation, an EHR upgrade and/or build-out of additional quality measures. Not surprisingly, this puts them a bit behind their peers because the scores will be published in late 2017 and stick with them throughout 2019. Those organizations that participated fully are more quickly moving from figuring out IT reporting issues to driving true performance improvement, and accordingly, higher quality category scores.
A survey SA Ignite released a few months ago said unsatisfactory reporting technology has caused systems to miss out on QPP incentives. Where specifically did vendors fall short?
Of survey responses, 64 percent of provider organizations indicated that they intend to maximize payment incentives associated with the QPP, yet 72 percent of those relying on their EHR to manage performance stated that their EHR did not have a solution. The biggest gaps were around the ability to see a MIPS score and the financial impact, and more importantly where to focus to improve performance. There was also a significant shortfall in receiving timely guidance from regulatory experts to navigate the complex and ever-changing rule.
The 2018 rule significantly increased the exemptions from MIPS. What should vendors and providers anticipate for participation requirements in 2019?
I don’t see CMS further relaxing the existing exemption requirements, so expect that the $90,000 threshold will remain the same or move lower in 2019. I do think CMS will need to address how they will handle voluntary reporting of exempt providers. I expect the public reporting piece to drive interest in submitting data so that clinicians can “have a number” like their peers.
The budget bill from Congress did slow down the implementation of the cost category in MIPS. How much trouble was this going to be for providers if it stuck to the old timetable?
The mandatory increase of the cost category to 30 percent would have been a struggle for many organizations. First, clinicians have very little experience being measured on a cost and second, moving the cost needle will take significantly more time and effort than raising the performance of a quality measure.
The recommendation by MedPAC to repeal MIPS attracted a lot of attention recently. How much concern is there in the industry that the program will be eliminated?
It’s important to remember why MIPS was created in the first place. No one wants to turn the clock back to the Sustainable Growth Rate formula and there is universal agreement that significant change needs to take place in order to reduce Medicare costs. There is also a fair amount of regulatory fatigue, so after consolidating three programs into one, there is little appetite to bite off yet another new regulation to support the same goal.
What sort of difficulties or challenges are Advanced APM participants facing compared to their counterparts in MIPS?
Not surprisingly, Advanced APM participants are facing challenges with managing their costs, in particular if their number of qualified participants is much lower than their full scope of services as an organization. Improving cost performance can sometimes occur at the expense of fee-for-service business and to the extent that the Advanced APM is a smaller part of their organization, the challenge is even greater.