The Quality Payment Program, established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), is a quality payment incentive for physicians and other eligible clinicians. MACRA is designed to provide incentives for value and improved outcomes through either the Merit-based Incentive Payment System (MIPS) or the Advanced Alternative Payment Models (APMs).
The first year of the program in 2017 will be a transition year for MIPS. The performance year begins on January 1, 2017 however clinicians do not have to report performance for the entire year and there are multiple paths for clinicians to avoid negative payment adjustments. MIPS eligible clinicians will only need to report on a minimum of one continuous 90-day period in 2017 for the majority of submissions. This 90-day period can occur anytime within 2017, as long as the period begins on or after January 1, 2017 and ends on or before December 31, 2017.
Furthermore, eligible clinicians have several participation options which, at a minimum, make it easy to avoid a negative payment adjustment, or possibly earn incentives for full participation. Your radiation oncology billing service should be able to help your practice pick one of the following paths.
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Participation Option |
Adjustment to 2019 Payment |
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Full Participation in MIPS. Report all measures required under the MIPS program, in all performance categories that require reporting, for a full 90-day period or the full calendar year. |
Eligible for maximum positive adjustment. Exceptional performers who achieve a MIPS Composite Performance Score of at least 70 out of 100 will be eligible for an additional positive adjustment from a bonus pool of $500 million. |
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Partial Participation in MIPS. Report more than one measure in the Quality category, more than one activity in the Improvement Activities category, or more than one of the required measures in the Advancing Care Information category for at least a full 90-day period. |
Clinicians who meet these requirements will avoid a negative payment adjustment and potentially earn a positive payment adjustment in 2019. |
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Minimum Participation in MIPS. Report one measure in the Quality performance category, report one activity in the Improvement Activities performance category, or report the required measures in the Advancing Care Information performance category. |
Clinicians who meet these requirements will meet the 2017 MIPS performance threshold (3 points) and avoid a negative 4% payment adjustment in 2019. With this level of participation, there will be no opportunity to earn additional incentive payments. |
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Participate in an Advanced APM. Participate in an Advanced APM in 2017 and meet the minimum Qualifying Participant payment or patient requirements. |
MIPS eligible clinicians participating in one or more Advanced APMs who receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM(s) will qualify for a 5% bonus incentive payment in 2019. |
Radiation Oncology Clinicians should also be aware that they can potentially earn up to 5 bonus points for the treatment of complex patients (based on a combination of the Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated). Contact your Radiation Oncology billing service for more information on this possibility.