According to a recent survey of healthcare finance executives, less than 25% of the respondents who reported they were somewhat or very confident in understanding CMS’ Quality Payment Program (QPP) requirements correctly answered 4% as the revenue at risk for eligible providers who choose not to participate in 2017; 60% of them either UNDER-estimated the amount or didn’t know.
The two new QPP payment models were created under the Medicare Access and CHIP Reauthorization Act (MACRA) legislation passed in 2015. Take, for example, that the less risky of the two models—the merit-based incentive payment system (MIPS)—starts out at putting 4% of payment at risk for reporting in 2017. That skyrockets to a whopping 9% by 2022. That’s a significant hit for any traditional fee-for-service payment environment.
CMS has upped the penalty ante
The same survey revealed only 5% of respondents classified themselves as completely ready to meet the QPP requirements in 2017. This general industry misunderstanding about QPP stems from a false read of the severity of its penalties based on perceptions of prior CMS programs. Having experienced more anemic regulatory attempts from CMS prior to now, many providers are assuming the QPP penalties are still at parity to the costs required to participate in the program.
This is a big mistake – CMS recognized that reality and, as a result, has put big teeth into its value-based care stick this time around. The ante is upped, and chief financial officers (CFOs) and other financial leaders need to let go of these leftover perceptions and take proactive steps now to protect their Medicare B reimbursements that will begin to take effect in 2019.
The CMS MACRA website is a wonderful free resource of information in determining QPP physician eligibility and exemptions, as well as options for program participation and reporting. But it can be cumbersome in determining what you need to do for your patients and your bottom line. To help, I’ve laid out my top three “must-knows” for understanding the new QPP:
Know the deadlines.
The first QPP reporting period started January 1 of this year. That reporting will affect Medicare payment adjustments beginning January 1, 2019. A key date to keep in mind is October 2, 2017. That is the last date to begin to report a 90-day period this calendar year. The other key date to keep in mind is March 31, 2018, which is the deadline to submit data for 2017. It is highly recommended not to wait for the deadlines. For a March 31 date, target February 15 for the last date to submit.
Know the importance of Clinical Documentation Improvement (CDI) and coding.
To put it bluntly, no one will do well with QPP without proper clinical documentation. Documentation for QPP requires much more specificity than previous physician quality reporting programs. Keep in mind that electronic health records (EHRs) are generally not implemented or mapped with an eye for reporting quality measures and not all versions of EHRs have the required capability to capture and collect the data, as well as create the necessary files for submitting QPP reports. Clinical documentation specialists (CDSs) are going to be the linchpin in identifying not only documentation issues, but opportunities for improved data mapping with your EHR vendors. There will be a significant focus on ICD-10 specificity and clarity, as well as Hierarchical Condition Categories (HCC), especially if you are considering participating in Alternative Payment Models (APMs). It’s imperative to take a hard look at your coding and clinical documentation improvement groups and processes now and not at the end of the year.
Know how clinicians are performing TODAY and get help with reporting.
Performance information that is weeks or months old simply isn’t going to cut it. Clinicians need real-time information for it to be actionable. Look for analytics solutions that can provide timely report cards for the five clinician groups included in 2017, and those proposed in future years. Also consider gaining the benefits of a using a partner that understands quality and has extensive history with CMS quality reporting. A qualified data registry that provides options for data submission offers instant feedback on whether your organization passed a measure. Unlike EHRs, these solutions were built for quality reporting. In addition, data registries offer drill down capabilities and reporting for feedback and staff education. When examining registry vendor options, look for registries that integrate with your EHR and your quality reporting solution, as well as vendors that encompass multiple specialties and a level of expertise to offer a one-stop shop.
MACRA is a complicated piece of regulation that delivers a new set of acronyms, plus the confusion of multiple options for payment models and reporting. While daunting, the stakes are too high to not take proactive steps now to prepare, plan and participate. It will help your organization retain what it earns in the short term, but also set the path forward to safeguard against severe penalties in the long term.