Medicare Quality Payment Program Under Fire

The American Hospital Association steps in; the American Medical Association steps up.

On Sept. 27, 2017, the Centers for Medicare & Medicaid Services (CMS) announced that it would not update its overall hospital quality star ratings in October 2017, as planned. This was primarily based on the public’s feedback, but the star ratings released last December will remain on the Hospital Compare website until the next update. The American Hospital Association (AHA) has been very vocal in suggesting that the current proposed Medicare Quality Payment Program (QPP) that began Jan. 1, 2017 is misleading. That program required that physicians who are eligible participate in either the Merit-Based Incentive Program (MIPS) or the Alternative Payment Model (APM). Those eligible that did not elect to join either program will receive a 4 percent penalty in their 2019 Medicare reimbursement.

As of Oct. 4, 2017, for those using the MIPS program, there are two requirements: a) clinicians are required to document care for patients and record data; and b) the performance reporting period that opened Jan. 1 closes Dec. 31. The final deadline for submitting complete data is March 31, 2018.

The good news is that the American Medical Association (AMA) outlined a “10 Key Steps Action Plan” for 2017 for MIPS. The steps include:

• Step One: Determine whether MIPS Applies to You
• Step Two: Review Available Performance Categories
• Step Three: “Pick Your Pace” for MIPS Participation
• Step Four: Review Your Data
• Step Five: Decide Whether to Report as Individual or a Group
• Step Six: Identify Your Reporting Mechanism
• Step Seven: Perform a Security Risk Analysis
• Step Eight: Report for at Least 90 Days (CMS Deadline was Oct. 2, 2017)
• Step Nine: Complete MIPS Performance CMS (Deadline was Dec. 31, 2017)
• Step Ten: Submit 2017 MIPS Data

What are the three major challenges facing the industry at this time?

• Most recognize that fee-for-service reimbursement payments will not survive, but are sensitive that “bundled payments” and electronic health record (EHR) punitive models have not survived.
• Providers do not understand the new QPP program and are sensitive as to when to embrace the new model seriously. The change in U.S. Department of Health and Human Services (HHS) leadership, with the departure of Tom Price, has also raised questions as to whether the new payment method will change.
• EHR systems (as sophisticated as they are today) are not prepared to report data.

Regardless, for now, the AMA recommendations allow providers to track their progress based on their guidelines, CMS deadlines, and successful adoption of MIPS.