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CMS Offers Options for Initiating Participation in New Payment Program

'Pick your pace' plan lets physicians choose method that 'makes sense for them,' ACP says

Physicians who aren't certain they're ready to fully participate in Medicare's new Quality Payment Program have gotten a bit of a break from the Centers for Medicare and Medicaid Services.

The program, which regulates how physicians will be reimbursed for seeing Medicare patients, will offer a "pick your pace" plan that lets physicians choose the time frame for their transition to the new system, according to the so-called "final rule" on the program, issued in mid-October. The Quality Payment Program was established to help implement the Medicare Access and CHIP Reauthorization Act (MACRA). It replaces the Sustainable Growth Rate payment system that CMS had used for years.

"This is a significant change intended to allow for physicians and practices to participate in a way that makes sense for them," said Shari Erickson, ACP's vice president for governmental affairs and medical practice. It allows physicians to "be protected from negative adjustments in 2019 and have the opportunity for positive adjustments," she said.

"Pick your pace" gives physicians four ways to start their participation in the Quality Payment Program:

  • Test the program by submitting minimal data
  • Participate for part of the 2017 calendar year
  • Participate for the full 2017 calendar year
  • Participate in an Advanced Alternative Payment Model (APM) in 2017
ACP members should choose one of the options, Erickson said.

"One of the key things that our members need to know is that if you haven't been doing any reporting under PQRS or Meaningful Use to date, if you're not feeling ready to participate fully or in a really significant way in a performance reporting type of program, you should choose one of the options," she said.

The reason, Erickson explained, is that you'll be protected from negative adjustments by choosing one of the four options and reporting as little as one improvement activity or quality measure. "If you don't report on anything, that's when you will get hit with a negative adjustment," she said.

What if you're worried that you're not doing any of the improvement activities? "There's a long list of improvement activities you can look at, and you're probably doing at least one thing on that list," Erickson said.

Indeed, "some of the listed metrics and activities might already be captured in current electronic records for initiatives you are already doing," said Dr. Robert McLean, a member of the ACP Board of Regents and chair of the College's Medical Practice and Quality Committee. "Some of this may be automatically occurring in the background of the electronic record functioning and not really require much or any extra work."

Physicians who have already been successfully reporting on PQRS and Meaningful Use or feel ready to report on all of the Merit-based Incentive Payment System (MIPS) categories of quality, improvement activities and advancing care information "can do so for either 90 days or a full year and have the best possible chance of a positive adjustment in 2019," McLean said.

"Even if doctors chose to participate in a limited manner in 2017 by reporting just one measure or activity, they should use 2017 to get ready for full reporting in future years," McLean said. "There is no guarantee that the 'pick your pace' options will be available after this initial reporting year."

More Information

Details on the Quality Payment Program are available from CMS. For guidance on MACRA issues, check out information on the ACP website. ACP also expects to have an interactive tool available online by end of the year.

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