- MACRA implementation has been a major priority for CMS in the past year, but the Department of Health and Human Service’s Office of the Inspector General (OIG) recently found several challenges that could impede Quality Payment Program success.
In the next year, OIG called on CMS to bolster guidance and technical support to ensure that eligible clinicians are prepared for Quality Payment Program participation. To help clinicians, CMS should also create health IT systems that support data reporting, scoring, and payment adjustments.
Boosting clinician readiness and backend health IT systems would especially help support solo providers, small practices, and rural hospitals, which has been a major pain point for many stakeholders during the MACRA implementation period.
“According to CMS staff, the QPP’s [Quality Payment Program] success relies in large part on clinicians’ acceptance of the program and readiness to participate,” OIG wrote. “However, stakeholders have expressed concerns about whether providers—especially solo, small-practice, and rural providers, who historically have been less likely to take part in CMS quality initiatives—will be technically and logistically ready to participate in the QPP.”
As a major MACRA implementation priority, CMS has taken steps to bolster clinician acceptance of and readiness for Quality Payment Program participation. The federal agency has performed Quality Payment Program Portal user tests, developed Clinician Champions, and awarded contracts for additional clinician education and support.
Notably, CMS also created a Quality Payment Program transition year. In 2017, eligible clinicians only have to submit data on one quality, improvement, or advancing care information measure under the Merit-Based Incentive Payment System (MIPS) to avoid a negative Medicare payment adjustment in 2019.
Moving forward, CMS plans to continue clinician engagement and outreach initiatives as well as provide more technical assistance contractor oversight.
However, OIG found solo, small-practice, and rural provider education lacking and identified clinician outreach and technical assistance as critical responsibilities for CMS in 2017. Without additional support, the Quality Payment Program may not be successful.
“CMS must ensure that providers—especially solo, small-practice, and rural providers—have the information and tools they need to participate in the QPP If providers lack the knowledge, tools, or skills to participate, they will struggle to meet the QPP reporting requirements,” wrote OIG. “Frustrated providers may even opt not to participate in the QPP despite the payment penalty, limiting the program’s ability to meet its goals.”
To overcome clinician outreach challenges, OIG recommended that CMS “continue to monitor clinician readiness—especially as the first reporting deadline approaches—to identify and address any problems early on.”
The federal agency should also expand clinician engagement and outreach activities to full scale throughout 2017 to ensure all Medicare clinicians understand and can participate in the Quality Payment Program.
Additionally, OIG called on CMS to develop and test backend health IT systems necessary for MACRA implementation, especially by 2019 Medicare payment adjustments. In 2017, CMS should create systems that support data submission and validation, MIPS final performance score calculations, payment adjustments, and other major Quality Payment Program functions.
In 2016, CMS focused on developing the Quality Payment Program public-facing website, but the program’s portal still needs individualized accounts for eligible clinicians and backend systems to support program functions.
CMS expects to launch individualized accounts by January 2017. With the accounts, CMS will be able to verify user identities, communicate Advanced Alternative Payment Model (APM) or MIPS track eligibility to clinicians, and provide performance feedback.
Later in 2017, the federal agency also anticipates to use the accounts to gather data on a clinician’s network of surrogates and vendors who report on the clinician’s behalf.
The Quality Payment Program service desk will also see an expansion in 2017, CMS told OIG. Beyond IT support, the service desk will be a resource for Quality Payment Program Portal and broader program assistance.
Despite CMS plans to finish the three-fold Quality Payment Program Portal, OIG advised CMS to make building backend systems a critical priority in 2017.
“Building and testing the extensive IT systems necessary to support critical QPP operations will require significant and sustained effort over the forthcoming year,” wrote OIG. “In the past, CMS has sometimes experienced delays and complications related to major IT initiatives, such as those required for the continued operation of Medicare Part D and HealthCare.gov.”
“If the complex systems underlying the QPP are not operational on schedule, the program will struggle to meet its goal of improving value and quality,” added the federal watchdog.
OIG also noted that CMS has taken steps to mitigate Quality Payment Program Portal risks by using legacy systems from other quality initiatives, such as the Physician Quality Reporting System and the Value-Based Modifier program.
The 2017 transition year will also give CMS more time to develop necessary IT infrastructure since many eligible clinicians will not be overwhelming existing systems with complete MIPS data submissions.
Additionally, the OIG report identified other MACRA implementation priorities, including adopting integrated business practices, facilitating Advanced APM participation, and developing additional MIPS policies.
The federal watchdog found that CMS has worked to achieve these MACRA implementation goals in a timely manner. For example, the federal agency created a Quality Payment Program strategy and assigned executive leadership to each program component.
Earlier this month, CMS also unveiled new Advanced APM options, including three cardiac and orthopedic care bundled payment models, a cardiac rehabilitation incentive program, and an additional Medicare Shared Saving Program track.
CMS also plans to continue working on MACRA implementation priorities, such as releasing more regulations and awarding additional contracts for clinician assistance. OIG did not identify any vulnerabilities in CMS plans to further these goals.