While important progress has been made by Centers for Medicare and Medicaid (CMS) towards implementing its new Quality Payment Program (QPP), meant to honor and reward providers for value-based care, there are susceptibilities that CMS must deal next year if the program is to succeed. That is the finding of a Department of Health and Human Services Office of the Inspector General audit which recognized 2 vulnerabilities that are crucial for CMS to deal in the year of 2017, involving providing sufficient guidance and technical help to make sure that clinicians are ready to participate in the Quality Payment Program (QPP), as well as establishing information technology systems to support data reporting, scoring and payment adjustment.
The final regulations have been released by CMS on October 14; the 1st performance year will start on Jan. 1, 2017, with the 1st payment adjustments taking effect on the day of Jan. 1, 2019. The Quality Payment Program is part of the execution of the Medicare Access and CHIP Reauthorization Act (MACRA) and hence will include Medicare Part B payments for about 600,000 clinicians. In order to participate, clinicians have 2 tracks from which to opt from—the Merit-Based Incentive Payment System (MIPS) or the Advanced Alternate Payment Models (Advanced APMs). The OIG repot notes, “As of the December 2016, CMS had decided significant policies to implement the Quality Payment Program, involving releasing final regulations and identifying Medicare models that qualify as Advanced APMs for the 1st performance period. Engagement and outreach tasks to clinicians have also been initiated by CMS, inaugurated a public-facing informational website, and granted several contracts for technical assistance and training.” Although, auditors also claimed that CMS “must still expand its technical assistance attempts, issue promised sub-regulatory guidance, award and oversee significant contracts, and complete development of backend information technology systems essential to support critical Quality Payment Program operations.” In accordance to the notice of OIG, CMS “confronts issues in building the complex backend IT systems needed to get data of clinicians, calculate their MIPS scores, and carry out other functions important to the success of program.” In accordance to the auditors, building and testing the extensive information technology systems essential to support critical Quality Payment Program operations will need significant and sustained effort over the upcoming year. In 2017, few key functions must be operational, while others will be required in the year of 2018. Although, “if the complex systems underlying the Quality Payment Program aren’t operational on schedule, the program will struggle to meet its aim of improving value and quality,” cautioned the OIG. A CMS spokesperson refused to particularly comment on the findings and suggestions of OIG, and rather referred to the agency’s official written response released in the audit report. In accordance to its written comments submitted to the OIG, CMS claimed that it is “committed to continuing to engage with and give help to clinicians, and to optimize backend information technology systems support, as it implements the Quality Payment Program (QPP).”
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