Last week The Centers for Medicare and Medicaid (CMS) Acting Administrator Andy Slavitt issued an official blog post announcing proposed reporting options for the Quality Payment Program (QPP), the program stemming from the Medicare Access and CHIP Reauthorization Act (MACRA), for program year 2017. The intent of these options is to give participants more flexibility during the initial year of this significant program.

For 2017, the blog post identifies four options:

1) Submit “test” data to CMS for any period of time within 2017. Choosing this option will eliminate any penalties from the MIPS program.

2) Submit complete data for a portion of program year 2017. Choosing this option will provide the opportunity for a partial incentive payment, if any is earned.

3) Submit complete data for all of program year 2017. Choosing this option provides the opportunity for a full incentive payment, if any is earned.

4) Participate in an advanced Alternative Payment Model, as outlined in the QPP rule.

Participating clinicians or practices do not need to finalize which of these four options they will choose until the point of attestation, which will be allowed only in early 2018. However, it is clear that the CMS intends these changes to ensure that all eligible clinicians see a path of some sort to participate in the program and avoid payment adjustments.

We do not yet know if the CMS will change reporting options for advanced Alternative Payment Models, nor what other adjustments the CMS might make in the final rule. While this post appears to offer new flexibility, Mr. Slavitt emphasized that questions about these options cannot be answered until the QPP final rule is issued, currently expected in October or November.

Until the details of the final rule are available, we advise clients to proceed with their plans for active and full participation in the QPP to ensure that they are ready for any option presented. For frequently asked questions about this subject, read A beginner’s guide to MACRA.

Contact Allscripts Consulting if you would like to schedule an introductory consultation.


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Former CIO / InfoSec Consultant / expert systems designer / Administrator for OB/GYN & OccMed practices / Family Therapist. Masters in Computer Science and Psychology; author of two books on artificial intelligence. In my "copious" free time I am a professional storyteller and inspirational speaker.


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