ASCRS and Medical Community Advocacy Prompts CMS to Announce Plans to Provide Flexibility for MACRA Start Date and Reporting Requirements
Providers May Choose to Submit Test Data to Avoid Penalties or Report for a Shorter Performance Period
Late this afternoon, Centers for Medicare and Medicaid Services (CMS) Acting Administrator Andy Slavitt announced in a blog post that the agency intends to offer flexibility for providers participating in the Quality Payment Program for the first performance year beginning in 2017. CMS released its Quality Payment proposed rule in April 2016—which implemented the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs) created under the Medicare Access and CHIP Reauthorization Act (MACRA)—and proposed that physicians would begin reporting on January 1, 2017, to impact Medicare payments beginning in 2019.
ASCRS and the medical community urged CMS to push back the start date of the new, complex program so physicians and practices would have time to learn about and implement the new system. In response to our advocacy, CMS announced it would offer the following options for participation in 2017, the first performance year:
First Option: Test the Quality Payment Program. Providers will avoid a negative payment adjustment, so long as they submit some data to the Quality Payment Program, including data from after January 1, 2017. CMS indicates this first option is designed to ensure that providers’ systems are working and that they can prepare for broader participation in 2018 and 2019.
Second Option: Participate for part of the calendar year. Providers may choose to submit Quality Payment Program information for a reduced number of days. This allows providers to begin their first performance period later than January 1, 2017, and still qualify for a small positive payment adjustment.
Third Option: Participate for the full calendar year. Providers may opt to begin on January 1, 2017, and choose to submit Quality Payment Program information for a full calendar year. Providers who report for a full calendar year would be eligible for a modest positive payment adjustment.
Fourth Option: Participate in an Advanced Alternative Payment Model in 2017. Providers may participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3, in 2017. Providers meeting payment or patient thresholds under the APM in 2017 would qualify for a 5% incentive payment in 2019. Please note: it is unlikely that most ophthalmologists are participating in an Advanced APM or would meet the required thresholds for 2017.
Acting Administrator Slavitt says in his blog post that full details relating to this optional flexibility will be included in the Quality Payment Program final rule, which is expected to be released no later than November 1, 2016.
ASCRS will alert our members when the final rule is released. If you need additional information, please contact Allison Madson, manager of Regulatory Affairs, at firstname.lastname@example.org or 703-591-2220.