March 21, 2018

Some significant regulatory changes could be coming this year to the Quality Payment Program (QPP) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as part of an effort to lighten clinicians’ administrative and quality reporting workloads.

The update comes from Kate Goodrich, MD, chief medical officer of the Centers for Medicare and Medicaid Services (CMS) and director of the agency’s Center for Clinical Standards and Quality, at a March 13 meeting in Washington, D.C.

The QPP has received steady criticism since its inception for, among other things, its complexity and the regulatory burden it places on physicians, which many argue strains the resources of smaller medical practices and impinges on time that should be spent interacting with and caring for patients.

In response, CMS has said it will explore ways to streamline the program and make participation less of a time and energy drain on clinicians.  For example, the agency is looking at how quality data could be extracted from electronic health records (EHRs) in a way that requires less time and effort, Dr. Goodrich said in an article about the meeting from the Healthcare Financial Management Association.  She said CMS is working with EHR vendors and data registries to identify methods of automatically extracting data for quality reporting from EHRs in order to free physicians from the administrative task.

Another potential program modification on the horizon is the alignment of quality measures between hospitals and employed physicians.  Though the measures for hospitals and physicians are fundamentally the same, the ways in which hospitals and physicians are required to work toward these quality goals are needlessly divergent, Dr. Goodrich explained.  The incongruence creates “problems for health systems that use a single electronic health record to report on behalf of clinicians and to report on behalf of hospitals,” she said.

CMS took some steps to remedy these problems toward the end of 2017.  In October, the agency announced the “Meaningful Measures” initiative in an effort to streamline measure sets, move from process measures to greater reliance on outcome measures and help providers zero in on the measures that have the greatest relevance to their practices and organizations.  In November, the agency also launched the CMS Measures Inventory Tool (CMIT), an interactive web-based application designed to give providers “improved visibility into the portfolio of CMS measures” in order to “promote the goal of increased alignment across programs and with other payers,” Dr. Goodrich wrote on the CMS Blog.  The tool is designed to increase transparency and “help coordinate measurement efforts across all conditions, settings and populations,” she said.

Other changes to the QPP will come from passage of the Bipartisan Budget Act (BBA) of 2018, which was signed into law by President Trump on February 9, 2018.  Among other things, the BBA gives CMS discretion to determine the scoring weight of the QPP’s Cost category within a range of 10 to 30 percent through 2021.  The change means that, conceivably, the Cost category could count for as little as 10 percent of the composite score for participants in the QPP’s Merit-Based Incentive Payment System (MIPS) through 2021—less than originally planned.  The BBA also removes Medicare Part B drug costs as a factor in MIPS payment adjustments.

While working to simplify the QPP, CMS will keep the transition to value-based payment as a “top strategic goal” by offering more advanced alternative payment models (APMs), according to Dr. Goodrich.  One of these models is Bundled Payments for Care Improvement Advanced(BPCI-A), which builds on some of the lessons learned in the original BPCI program begun in 2013.  BPCI-A will qualify as an APM in the QPP, which means participants will be exempt from MIPS reporting requirements.

Despite the anticipated changes, CMS is holding fast in requiring providers to meet the 2015 standards for Certified Electronic Health Record Technology (CEHRT) starting in 2019 in order to meet requirements in MIPS’s Advancing Care Information category, Dr. Goodrich said.  For 2018, providers were allowed to use 2014 CEHRT products.  “We’ve delayed this a couple years, but last year we finalized that this would be required starting in 2019; we are not backing down on that,” she said.

A 2017 survey of hospital and physician practice leaders found that only nine percent of participants had implemented 2015 CEHRT products, but another 41 percent reported that they were in the process of doing so.

CMS is expected to make its first announcements about changes to the QPP later this month.