Andy Slavitt, Acting Administrator of CMS, gave us a sneak preview on Sept. 8 of what is coming in the final rule that outlines the Quality Payment Program (QPP) that is due to be published by November 1, 2016.
Summary: Many comments on the Proposed Rule suggested that implementing MIPS will be difficult, particularly for small practices. This sneak preview, from Slavitt, said that CMS is going to ease into the MIPS requirements and allow practices four options to participate with varying levels of data requirements.
The first option just avoids the penalty, the second makes it possible to earn a small incentive and the third option makes them eligible for the full incentive. The fourth option is to participate in an Advanced Alternative Payment Model.
What is striking about this message is two things:
- CMS is listening to comments.
- There is still not quite enough information to know exactly what will be required to avoid the penalty or earn a “small positive payment adjustment.”
The descriptions of the first two options, which say sending “some” data or data from a reduced number of days, are just too vague to draw conclusions about what “some” means and exactly what will be required to qualify to avoid the penalty or earn the incentive.
Based on this sneak preview, then what should you do to get ready for MIPS?
Our thoughts are “don’t do anything different.”
- Prepare your 2016 PQRS submission to avoid the PQRS and Value-Modifier penalties and select measures that you perform well on for Quality Tiering.
- Review the Clinical Practice Improvement Activities to see which activities you are already doing or planning to implement.
- Make sure your EMR is certified to the 2014 Edition.
- Get a copy of your Quality and Resource Use Report (QRUR) to see how you compare with other practices.
There is simply not enough information in Slavitt’s message to do a lot more.
When the final rule is out by November 1, 2016, talk to our knowledgeable Quality Reporting Consultants to choose a MIPS “Pace” that works for you.
This eBook will help you prepare for the transition to MIPS and APMs.