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CMS Releases Draft Plan for Transition to New Payment Models

December 22, 2015
by Rajiv Leventhal
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The Centers for Medicare & Medicaid Services (CMS) has released a Quality Measure Development Plan (MDP) to serve as a strategic framework for the future of clinician quality measure development as healthcare transitions to the new Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs).

In addition to repealing the long-maligned sustainable growth rate (SGR) formula for Medicare physician payment, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), signed into law earlier this year, ends physician payment incentives  under the meaningful use program within the HITECH (Health Information Technology for Economic and Clinical Health) Act, and those under the Physician Quality Reporting System (PQRS), replacing the incentives in those programs with a new program called the Merit-based Incentive Payment Program, or MIPS. Physicians will also be able to opt for an alternative program involving slightly higher payments in return for participation in certain alternative payment models, or APMs.

According to a Healthcare Informatics report from when the legislation was signed into law, under the new MIPS, to be applied to payments beginning Jan. 1, 2019, the Secretary of Health and Human Services would “assess appropriate adjustments to quality measures, resource use measures, and other measures used under the MIPS; and… assess and implement appropriate adjustments to payment adjustments, composite performance scores, scores for performance categories, or scores for measures or activities under the MIPS.”

Now, the purpose of the CMS Quality Measure Development Plan is to meet the requirements of the statute and serve as a strategic framework for the future of clinician quality measure development to support MIPS and APMs, CMS said in the plan, which was released on Dec. 18. The MDP highlights known measurement and performance gaps and recommends approaches to close those gaps through development, use, and refinement of quality measures, the plan stated.

According to the plan, beginning in 2019, CMS will apply a positive, negative, or neutral payment adjustment to each MIPS eligible professional (EP) based on a composite performance score across four performance categories: quality; resource use; clinical practice improvement activities; and meaningful use of certified electronic health record (EHR) technology.  Measures for use in the quality performance category are a specific focus of the MDP. MIPS will build upon existing quality measure sets from PQRS, Value-based Payment Modifier (VM), and meaningful use.

To fill identified measure and performance gap areas, CMS will expand and enhance existing measures to promote alignment and harmonization in the selection of measures and specifications, while concurrently developing new (de novo) measures according to priorities, the plan said. “MACRA establishes incentive payments for EPs participating in certain types of APMs,” the plan stated. “MACRA requires quality measures used in APMs to be comparable to the quality measures used in MIPS; therefore applicability of candidate measures to support a variety of future APMs is an important element,” it said.

MACRA identifies five quality domains (i.e., clinical care, safety, care coordination, patient and caregiver experience, population health and prevention) for measures developed under the MDP, which align with the National Quality Strategy and the CMS Quality Strategy, the plan said.

“CMS is also taking into consideration the quality domain of efficiency and cost reduction. MACRA further establishes priorities for the types of measures to be developed, which shall  include outcome, patient experience, care coordination, and measures of appropriate use of services, such as measures of overuse,” the plan said.

CMS said that it welcomes comments on this draft plan from the public, including healthcare providers, payers, consumers, and other stakeholders, through March 1, 2016. The final MDP, taking into account public comments on this draft plan, will be posted on the CMS.gov website by May 1, 2016. The MDP will be updated annually or as otherwise appropriate to report progress, including activities conducted during the year, newly identified measure gaps, and challenges encountered, the agency said.

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