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Are you Ready For Medicare Payment Adjustments?

News From SVS | First Data Collection Year Coming to an End

SVS members have a narrow window remaining to participate in the Quality Payment Program (QPP) this year and avoid a 4 percent Medicare reimbursement penalty in 2019. The final 90-day reporting period began Oct. 2.

The implementation of the Quality Payment Program has been heading members’ way since 2015, when the Medicare Access and CHIP Reauthorization Act (MACRA) ended the Sustainable Growth Rate Formula and the Physician Quality Reporting System, the Value-based Payment Modifier, and the Meaningful Use of Electronic Health Records that previously determined a physician’s annual Medicare payments.

Data collected this year must be submitted by March 31, 2018. Medicare will provide feedback in 2018 and payment adjustments begin Jan. 1, 2019. The performance data includes the care a participant provided and how his or her practice used technology in 2017.

"All these programs have a two-year lag; physicians report 2017 data for payment in 2019," said consultant Jill Rathbun, who has presented several webinars on the changes for SVS members. "If you don’t report on quality measures or clinical improvement activities in 2017, there’s no way to fix it in 2018 to avoid the 4 percent penalty on 2019 Medicare payments."

Members conceivably can go through patient care records dating to Oct. 2, collect that information through the end of the year and submit it by the March 31, 2018, deadline, she said.

Most physicians who treat Medicare Part B patients – a minimum of 100 a year or billing a minimum of $30,000 a year – now must participate in the new Quality Payment Program, created by the MACRA law.

That program has two tracks from which to choose:

• Advanced Alternative Payment Models (APM)

• The Merit-based Incentive Payment System (MIPS)

No Advanced APMs specifically for vascular surgeons currently exist – though an SVS task force is working on developing APMs related to dialysis access and peripheral vascular disease – so SVS members must participate in MIPS or an APM through their group, with payment adjustments based on performance. The Centers for Medicare and Medicaid Services estimates 500,000 providers are eligible to participate in MIPS this year.

The QPP has four performance categories for MIPS. A provider’s MIPS score is based on Quality (60 percent); Advancing Care Information (25 percent) and Improvement Activities (15 percent). The fourth category, Cost, is not being counted this year.

For the 2017 reporting year/2019 payment year, CMS has created a transition pathway where surgeons, reporting as either a group or as an individual, pick one of four participation options:

• No participation in QPP: Those who don’t submit any 2017 data will see a 4 percent reimbursement penalty.

• Test: Those who submit a minimum amount of 2017 data, such as one quality measure or one improvement activity for any point in 2017, can avoid the negative adjustment and receive a neutral adjustment.

• Partial: Those who submit 90 days of 2017 data may earn a neutral or positive payment adjustment, perhaps receiving the maximum adjustment.

• Full: Those who submit a full year of 2017 data may earn a positive payment adjustment.

The size of the potential payment adjustment will depend both on how much data is submitted and the quality results, said CMS officials.

MIPS replaces three Medicare reporting programs (Medicare Meaningful Use, the Physician Quality Reporting System, and the Value-Based Payment Modifier). While the three programs will end in 2018, those who have participated in these programs in the past will have an advantage in MIPS because many of the requirements should be familiar.
Avoid Reimbursement Penalties; Join VQI Today

With the reporting requirements now in place for Medicare reimbursement, now is the perfect time for SVS members to participate in the SVS Vascular Quality Initiative. VQI includes a CMS-approved registry, as well as peer mentoring, benchmarking and education opportunities designed to advance quality improvement locally through regional quality groups. Such data will be essential in helping members participating in the Merit-based Incentive Payment System (MIPS).

Visit vascularqualityinitiative.org. Members also may email vqi@m2s.com or call (603) 298-5509.
Steps to take

• Determine if you have to participate at www.qpp.cms.gov. Surgeons will need their 10-digit National Provider Identification number. Physicians in a group should check all members’ status, as it’s possible individual statuses could vary.

• Pick a measure to submit. "Use filter terms," advised Rathbun. She narrowed the list of nearly 300 quality measures to a much more manageable list by applying such filters as "vascular," "vascular surgery," "reportable by claims" and "high-priority measures."

• After selecting the measure, visit www.qpp.cms.gov; go to the "resource library" and download the file entitled, "measure specifications," to obtain the coding instructions to report the quality measures you have selected.

• Surgeons also can document Improvement Activities or Advancing Care Information and then attest to having performed those activities via the CMS website.
Visit the QPP website for more

The CMS’ Quality Payment Program website (www.cms.qpp.gov) is a treasure trove of information on MACRA, MIPS and APMs. It offers, timelines, requirements and scoring, categories, registry listings, 2017 Quality Benchmarks and Quality Measure Specifications. These last "are hugely important," said consultant Rathbun. "It tells you what CPT code(s) have to be reported and what you report on the claims to show you did or did not do the measure."

The website also includes, among other references, a list and links to all the webinars CMS has done on MACRA and QPP.