On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) released its 2018 final rule, reflecting updates and changes to the Medicare Access and CHIP Reauthorization Act’s (MACRA) Quality Payment Program (QPP). The 2018 rule, which implements changes to the two pathways for clinicians participating in Medicare fee-for-service: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs), can be seen in many ways as a response to concerns raised since the QPP was first announced regarding resource and workflow burden, as well as the overall complexity of the elements to successfully report.
As the end of the QPP’s first year rapidly approaches, CMS has maintained flexibilities from the 2017 transition year in an effort to help clinicians prepare for 2019, when full implementation of the rule takes hold. And with the first reporting submission deadline of March 1, 2018, for MIPS participation nearing quickly, it is evident that such flexibility is warranted, as eligible providers across the care continuum remain at varying levels of readiness for this new era of physician payment. Part of that variability likely stems from providers feeling overwhelmed with MIPS requirements. According to the Medical Group Management Association’s 2017 Regulatory Burden Survey, the QPP topped respondents’ list of issues they see as “very” or “extremely” burdensome. In addition, more than 70 percent of group practices said they view the MIPS scoring system as “very” or “extremely” complex.
Concerns about the resource and workflow burden, as well as the complexity of the Act, have not gone unnoticed. On October 30, 2017, just days prior to release of the 2018 final rule, CMS Administrator Seema Verma addressed a series of efforts the agency has underway to streamline quality measures, reduce regulatory burden and promote innovation across the healthcare landscape. In addition to highlighting CMS’ work to implement the QPP in a way that minimizes the burden and costs providers face in meeting the requirements, Administrator Verma unveiled the agency’s new “Meaningful Measures” initiative, which will focus on the use of outcomes-based measures to assess those core issues that are most vital to providing high-quality care and improving patient outcomes.
Industry stakeholder response to the 2018 final rule has been largely positive, with many voicing strong support for CMS’ decision to maintain the transitional nature of the program for 2018. For more information about the specific changes in the final QPP rule and how they impact strategy and planning among organizations across the healthcare ecosystem, please read part 2 of the series.