HHS provides funding for training small practices in Quality Payment Program

HHS will provide $20 million in funding that will be used to train Medicare clinicians in small practices on the Quality Payment Program. These funds will be primarily directed toward clinicians practicing in underserved areas, including rural areas and health professional shortage areas. This amount of funding will be provided annually for the next five years.

Quality Payment Program

The proposed Quality Payment Program would implement the changes created by Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which reformed clinician payment for serving Medicare patients. The proposal streamlined various value and quality programs into two paths. Under the program, physicians would be able to choose from the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs) (see Physician reporting streamlined, less burdensome under flexible Quality Payment Program, Health Law Daily, April 28, 2016).

Under MIPS, physicians would submit information about four performance categories. Then, a composite performance score is generated and compared against a threshold. This threshold determines the payment adjustment. Under APMs, physicians would receive a lump sum payment that could grow annually.

Small practices

Secretary Burwell emphasized the administration’s commitment to providing resources to small and rural practices that will allow them to provide quality care. Organizations must show that they are able to provide training to individual clinicians or small group practices of no more than 15 clinicians to become eligible for funding. The training would include creating a strategy for Quality Payment Program participation, such as adding electronic health record (EHR) capability, joining an APM, and evaluating practice workflow.

Proposed MIPS rule requires new vocabulary for physician payments

When CMS published the advance release of a Proposed rule to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) (P.L. 114-10), it changed existing and created new terms and acronyms to describe aspects of the Merit-based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) incentive under the physician fee schedule (PFS). As providers and health lawyers prepare to adjust to MACRA’s changes, they should also train themselves to be conversant in this new language.

New language

MACRA created a number of new terms, most of which are used in the Proposed rule. A few of the terms MACRA created have been changed in the Proposed rule; see Obsolete terms, below.

APM: For the purposes of the APM incentive, MACRA defines an APM as a model under section 1115A of the Social Security Act (the Act) (excluding a health care innovation award), the Shared Savings Program under section 1899 of the Act, a demonstration under section 1866C of the Act, or a demonstration required by federal law.

Other Payer APMs: The Proposed rule uses this term to refer to arrangements in which eligible clinicians may participate through other payers.

APM Entity: Under the Proposed rule, an APM Entity is an entity that participates in an APM through a contract with a payer.

Qualifying APM Participant (QP) / Partial Qualifying APM Participant (Partial QP): These terms, defined in Act secs. 1833(z)(2) and 1848(q)(1)(C)(iii) do not report on MIPS applicable measures and activities that are required under MIPS. QP and Partial QP status is determined based on participation in Advanced APMs during a corresponding QP Performance Period.

MIPS eligible clinician:  The Proposed rule uses this term to replace MACRA’s wording of MIPS eligible professional (EP), defined at Act sec. 1848(q)(1)(C). MIPS eligible clinicians will include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups that include such clinicians. This definition does not include QPs and Partial QPs.

 

Obsolete terms

Sustainable growth rate (SGR): MACRA ended the SGR, which came from a 1997 law aiming to control Medicare costs. The SGR has been rendered ineffective for more than a decade due to Congressional “doc fixes.”

Physician Quality Reporting System (PQRS); Physician Value-based Payment Modifier (VM); Medicare Electronic Health Record Incentive Program for Eligible Professionals, also known as the Meaningful Use program: These three programs will sunset after 2018, while some elements of each will be incorporated into MIPS, which begins in 2019.

MIPS EPs: The Proposed rule would define MIPS program participants as “MIPS eligible clinicians” rather than “MIPS EPs.” The agency believes that eligible clinicians is a more flexible, inclusive term than EP.

“All-or-nothing” scoring: The PQRS required EPs to meet all program criteria or receive a negative adjustment. The Proposed rule instead would give MIPS eligible clinicians partial credit, rewarding them partially for the measures they do meet.

For Wolters Kluwer’s analysis of the Proposed rule, see Physician reporting streamlined, less burdensome under flexible Quality Payment Program, Health Law Daily, April 28, 2016.