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OIG Identifies Vulnerabilities in CMS’ Deployment of MACRA

December 29, 2016
by Rajiv Leventhal
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The Department of Health and Human Service’s (HHS) Office of the Inspector General (OIG) has identified two vulnerabilities related to MACRA that the department says the Centers for Medicare & Medicaid Services’ (CMS) must address.

MACRA, or the Medicare Access and CHIP Reauthorization Act of 2015, enacted clinician payment reforms designed to put increased focus on the quality and value of care. These reforms, known as the Quality Payment Program (QPP), are a significant shift in how Medicare calculates compensation for clinicians and require CMS to develop a complex system for measuring, reporting, and scoring the value and quality of care.

Federal officials released a final rule for MACRA in October with the first performance period set to begin in just a few days on Jan. 1. However, CMS also has announced flexibilities that will allow eligible Medicare physicians to pick their pace of participation for the first performance period of MACRA that will enable physicians to ease into the program without getting hit with negative payment adjustments right away. CMS referred to these flexibilities as “picking your pace.” Clinicians may participate in one of two QPP tracks: the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs).

As such, OIG officials recently interviewed CMS staff and reviewed internal CMS documents as well as publicly available information. The department conducted qualitative analysis to identify key milestones (both those achieved and those yet to come), priorities, and challenges related to QPP implementation.

While OIG said that CMS has made significant progress towards implementing the QPP, it identified two vulnerabilities that are critical for CMS to address in 2017, because of their potential impact on the program's success: (1) providing sufficient guidance and technical assistance to ensure that clinicians are ready to participate in the QPP, and (2) developing IT systems to support data reporting, scoring, and payment adjustment.

It also identified CMS's five key management priorities regarding the agency's planning and early implementation of the QPP. According to OIG, early on, CMS staff decided that clinicians' acceptance of the QPP, and readiness to participate in it, would be the most critical factor to ensuring the program's success. This focus on clinicians informed CMS's decision making regarding its other management priorities, including:

  • adopting integrated internal business practices to accommodate a flexible, user-centric approach;
  • developing IT systems that support and streamline clinician participation;
  • developing flexible and transparent MIPS policies; and
  •  facilitating participation in Advanced APMs.

As of December 2016, CMS had finalized key policies to implement the QPP, including issuing final regulations and identifying Medicare models that qualify as Advanced APMs for the first performance period. CMS had also initiated engagement and outreach activities to clinicians, launched a public-facing informational website, and awarded various contracts for technical assistance and training. “CMS must still expand its technical assistance efforts, issue promised sub-regulatory guidance, award and oversee key contracts, and complete development of backend IT systems necessary to support critical QPP operations,” OIG reported.

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