CMS released a new Quality Payment Program proposal on April 27, 2016. This program was developed as directed in MACRA, the legislation enacted April 16, 2015 that repealed the SGR and replaced it with a Merit-based Incentive Payment System (MIPS) for providers currently paid under the PFS. The purpose of the rule is to establish policies for provider payments by changing the way Medicare links quality reporting to provider payment and to incentivize participation in alternative payment models.
The Department of Health and Human Services has three goals: provider payment based on outcomes and quality instead of quantity, improve healthcare delivery efficiency and improve healthcare data availability. The timeline for achieving these goals is below:
2016: 30% of FFS payments based on value and provided through APMs.
2018 50% of FFS based on value and provided through APMs that base payments on quality of care.
2020: Private payer goal: 75% of contracts designed to improve quality and lower costs.
The rule establishes two tracks of performance based pay, one for Advanced APMs and the other “MIPS” for all other providers. Most of our members will fall into the MIPS track.
Under MIPS, data will be collected in four key areas:
- Quality
- Resource Use
- Clinical practice improvement activities
- Advancing Care Information (EHR or “meaningful use”)
These categories will be weighted and performance in each will be combined to determine a CPS or Composite Performance Score. This score will determine whether providers are eligible for a payment incentive, neutral or payment reduction. Just like PQRS, data will be collected on an annual basis, with the resulting payment adjustments taking effect two years from the collection year. The program begins for certain providers January 1, 2017, so their payment adjustments would take place in 2019.
The Good News: Physical and occupational therapy is not included in the program at this time. Communication with CMS trainers indicates that therapy providers most likely will be added in 2019.
The Bad News: Therapy providers are not eligible for the incentives, meaning that reimbursement updates will be limited to .5% increases over the next two years as legislated in MACRA.
The Federal and State Committee, along with the CMS taskforce, advised the Board of Directors on a response to the proposed rule.