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Christian 
Vice President
Government Affairs & Client Programs

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After collecting feedback on the proposed Quality Payment Program set to begin January 1, 2017, CMS announced preliminary changes that it will allow providers to pick their pace for the first performance year. The first performance year is scheduled to begin January 1, 2017. The announcement states that eligible physicians and clinicians will have four options to select from during the first performance year, ensuring providers will not receive a negative payment adjustment in 2019. Additional details regarding this option and other modifications to the program may be announced as part of the Final Rule expected before November 1, 2017. An abbreviated version of the CMS options:

An abbreviated version of the CMS options:

Option 1: Test the Quality Payment Program 
The first option states that as long as eligible clinicians submit some type of data to the Quality Payment Program, including “some data” starting on or after January 1, 2017, they will not receive a negative payment adjustment in 2019. This will give eligible clinicians enough time to ensure their system is working and they are prepared for full participation in 2018.

Option 2: Participate for Part of the Calendar Year 
Eligible clinicians may submit Quality Payment Program data for a reduced number of days. Eligible clinicians may begin their performance period after January 1, 2017 and still qualify for a small positive payment adjustment in 2019. Eligible clinicians can select from the list of quality measures and improvement activities available under the Quality Payment Program.

Option 3: Participate for the Full Calendar Year
If your practice is ready to go on January 1, 2017, you may submit Quality Payment Program information for the full calendar year and could qualify for a modest positive payment adjustment.

Option 4: Participate in an Advanced Alternative Payment Model in 2017
The new mandate will allow eligible clinicians to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such Next Generation ACO in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.

As mentioned, CMS plans to release the final rule for the Quality Payment Program by November 1, 2016. The final rule will include more comments and information regarding other changes to the program. After the final rule is released, TSI Healthcare will host informational webinars for our clients to review the final changes to the Quality Payment Program set to begin January 1, 2017!

For additional resources visit our MACRA page.

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