The Centers for Medicare & Medicaid Services (CMS) released its first annual report March 20 on provider participation in the Quality Payment Program (QPP), revealing some interesting statistics.
The report showed:
- 95 percent of clinicians avoided a negative payment adjustment under the Merit-based Incentive Payment System (MIPS).
- Participation rates for small practices were considerably lower, at 81 percent.
- About 99,000 physicians qualified for the 5 percent bonus for participating in advanced alternative payment models (APMs).
There was considerable flexibility in how many measures to report. For instance, to avoid a negative adjustment in 2019, participating clinicians had to report only one measure in 2017 and could report data for less than 90 days for Advancing Care Information, Quality, and Performance Improvement Activities. However, less than 1 percent of participants elected to submit the minimum amount of data and report a performance period of less than 90 days.
The maximum adjustment for providers that did not receive an “additional adjustment for exceptional performance” was 0.2 percent (22 percent of MIPS-eligible NPIs/TINs), while the maximum for those receiving an “additional adjustment for exceptional performance” was 1.88 percent (71 percent of MIPS eligible NPIs/TINs received an exceptional performance adjustment).
- Welcome to Lake Woebegon, where all providers are exceptional. While this was intentional to allow providers to adjust to the new program, it isn’t differentiating or rewarding exceptional performance as was intended by Congress. And the financial upside to performing well in MIPS isn’t sufficient now, nor will it be in the future, to offset the failure of Medicare Physician Fee Schedule increases to keep up with practice-expense inflation.
The bar is raised in 2018 and 2019 as to the number of measures clinicians must report and the length of time they must report on the measures. The new bar will start to differentiate the field. However, the number of participants will also decrease, which will reduce the potential dollars available to high-performers.
- As expected, there is a significant gap in the participation percentage of small practices: 81 percent of eligible small practices versus 95 percent for the average-sized practice. Because reporting the data accurately is administratively burdensome, it appears some small practices have made the calculation that it is cheaper to incur the penalty than to invest in the resources to accurately report the data. CMS’s solution to this challenge is to widen the exclusions from $30,000 in Part B revenue or 100 beneficiaries for 2017 to $90,000 in Part B revenue or 200 beneficiaries in 2018 and beyond.
Based on CMS’s estimates, this will significantly reduce the number of providers that are compelled to participate in the program. Although it does address small-practice concerns to some extent, it does not drive smaller practices, where a large percentage of the population receives its care, to deliver more efficient, higher-value care. CMS in early projections estimated that smaller practices would be net contributors to the MIPS redistribution, so this will also reduce the rewards available to high-performers.
- Finally, in Table 7 on page 12 of the whitepaper, CMS reported the average payment and patient count threshold score for the various APM participants. Participants in population health models cleared the 50 percent of Part B payment or 35 percent of Medicare patient population thresholds to qualify for the advanced APM bonus in the 2019 performance year (2021 payment year). However, on average, participants in the Comprehensive Care for Joint Replacement program failed to meet either threshold for the 2017 performance year, which is considerably lower (25% of Part B payments or 20% of Medicare patients).
While it may be too early to read into this statistic, it implies that specialists who are participating in Bundled Payments for Care Improvement Advanced may struggle to qualify for the 5 percent advanced APM bonus unless they also are participating in a risk-bearing Medicare Shared Savings Program or Next Generation Accountable Care Organization.