The majority of providers thought they could breathe easy after the Medicare Access and CHIP Reauthorization Act, or MACRA, legislation was finalized last October. Their prayers had been answered; quality reporting programs had been eliminated and the burden of reporting data at the risk of a hefty penalty had been lifted… or so they thought. Once the praise and excitement settled, providers realized these programs weren’t going away at all they were just being rebranded. There is no doubt the new Quality Payment Program established by MACRA has improved, but little has been done to truly ease the reporting burden thrust upon our providers. Until that is, our friends at the Centers for Medicare and Medicaid Services (CMS) issued the Pick Your Pace option for those participating under MIPS in 2017.
This option allows providers to choose the level at which they would like to participate for 2017, which has been deemed a “transition year”. Providers can choose to submit nothing, submit something, submit a partial year, or submit a full year of data (any providers participating in an APM under MACRA please accept my deepest apologies, these options don’t apply to you). So what exactly do these 4 tiered participation tracks entail?
- Submit Nothing. Providers can choose to submit absolutely nothing to CMS and they will see a negative 4% payment adjustment. Come on folks, we can do better!
- Submit Something. Providers can sit back and report one data point, that’s right just one measly little measure and they would be in the clear receiving no negative (or positive) adjustment.
- Submit a Partial Year. Ding, ding we have a winner!! This, my friends, is the best option in my humble opinion. Providers submit data that meets all of the requirements under MIPS for 90 days.
- Submit a Full Year. Providers can fully participate by starting January 1, 2017 and report a full year’s worth of data for all requirements under MIPS. Wait a minute, we are already 3 months into 2017…. This is why I said you better pick your pace quickly.
So why am I “partial” to submitting a “partial” year’s worth of data? Well, if there is one thing I hope you take away from this post it’s that:
Positive adjustments are based on the performance data, not the amount of information or length of time submitted.
No more thresholds, no more pass/fail with an all-or-nothing framework, it is truly about the performance rates providers have for measures that (are supposed to) reflect the quality of care they are providing their patients. This is what matters, the quality of data not the quantity.
Providers and their clinical staff are facing an uphill battle tackling this new program, its requirements and new scoring methodologies. There is a long list of decisions to make with many choices, will you choose to just keep your head above water or will you attempt to master the program and leverage your data to improve quality? It’s time to pick your pace.
- Lindsey Lanning, Healthcare Compliance Consultant at Itentive Healthcare Solutions