CMS’ Quality Payment Program (QPP), launched in 2016 as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), offers clinicians a “pick your pace” approach to help reduce their quality measurement and administrative burden.
The recently released QPP Year 2 proposed rule targets reporting from 2018 onward and extends to cover certain aspects of the Appropriate Use Criteria (AUC) and the 21st Century Cures Act. The updates also include measures such as improvement scores, which were proposed in MACRA but were not implemented in Year 1.
Here are eight key takeaways from the QPP Year 2 proposed rule, which could be finalized in November 2017, based on CMS’ past release schedules.
1. Improvement scores matter
The improvement score, measured at the quality performance category level, will be based on the performance increase from last year, scaling up to 10 percentage points. With the addition of improvement scores, providers can prevent repetitive reporting of the same measures and performances. This will encourage providers to strive for the highest score every year of the Merit-based Incentive Payment System (MIPS), regardless of how well they did the previous year. Providers should take advantage of analytics for real-time score improvements and comparison with peers.
2. Factor cost into performance measurement
Although cost doesn’t require reporting, it affects the bottom line as far as the composite performance score (CPS) and payment adjustments are concerned. Because CMS is keeping the cost weightage low at zero or 10% initially, providers have a chance to adjust to this new category. However, the cost weightage will jump to 30% starting in 2019, so participants relying on quality scores will need to monitor their costs and start preparing for the huge impact this category will have from 2019. This will require an investment in analytics to leverage Quality and Resource Use Reports (QRUR) and to help optimize costs.
3. Availability of new submission mechanisms
While the allowance of more than one submission mechanism (such as Qualified Clinical Data Registry (QCDR), Qualified Registry (QR), Certified Electronic Health Record Technology (CEHRT), CMS Web Interface, etc.) within the same performance category is commendable, it will amount to a huge burden for health IT developers to incorporate such flexibility within the system. To minimize confusion and complexity in the submission process, providers should stick with one submission mechanism across all four categories, which would satisfy use cases.