HHS Office of Inspector General flags MACRA vulnerabilities related to clinician awareness, program integrity

The Health & Human Services (HHS) Office of the Inspector General (OIG) in December 2017 released a report indicating that with regard to the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA), the Centers for Medicare and Medicaid Services (CMS) continues to face vulnerabilities related to clinician awareness of MACRA’s Quality Payment Program (QPP) and program integrity to avoid fraud and improper Medicare Part B payment adjustments.

In a similar report from 2016, HHS OIG highlighted vulnerabilities related to providing guidance and technical assistance to clinicians and to developing information technology (IT) systems to support data reporting, scoring and Part B payment adjustments. HHS OIG found that CMS has made “significant efforts” to address these vulnerabilities.

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CMS releases part II of the 2019 Medicare Advantage and Part D Advance Notice and Draft Call Letter

The Centers for Medicare and Medicaid Services (CMS) on February 1, 2018, released the second part of the 2019 Medicare Advantage (MA) and Part D Advance Notice, and the Part D draft Call Letter, proposing average increases to MA payment rates for 2019 of 1.84% plus a potential further increase of 3.1% as a result of expected changes to risk scores for MA Plans.

The first part of the Call Letter was released on December 27, 2017, in compliance with provisions of the 21st Century Cures Act that require CMS to fully implement changes to the Medicare risk adjustment model by 2022.

Comments for both parts of the proposed Advance Notice and the Part D Call Letter are due to CMS by March 5, 2018. CMS expects to publish the final 2019 Rate Announcement and final Call Letter by April 2, 2018.

Highlights of key provisions of the advance notice and draft call letter are provided below.

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CMS announces new voluntary bundled payment model

On January 10, 2017, the Centers for Medicare and Medicaid Services (CMS) through the Center for Medicare and Medicaid Innovation (CMMI) announced a new Medicare bundled payment model, Bundled Payments for Care Improvement Advanced (BPCI-Advanced), which will be an advanced alternative payment model (AAPM) under the Medicare Access and CHIP Reauthorization Act’s (MACRA) Quality Payment Program (QPP). The model establishes alternative payment structures for 32 distinct clinical episodes, where providers can participate on a voluntary basis and receive performance-based payments for delivering care at less than a target amount and meeting quality standards.

Following on the 2013 CMMI BPCI initiative, BPCI-Advanced demonstrates CMS’ continued support of bundled payments on a voluntary basis to encourage both providers and suppliers to coordinate care across multiple settings and meet cost and quality benchmarks. This program is intended as an opportunity for providers to gain experience in care coordination and shared payment structures on their own terms. Details on BPCI-Advanced are described below.

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CMS proposes to scale back scope of bundled payment model for joint replacement, cancel other mandatory bundled payment models

The Centers for Medicare and Medicaid Services (CMS) on Thursday, August 17, 2017, published a proposed rule that would reduce the number of geographic areas where hospitals and clinicians would be required to participate in the Comprehensive Care for Joint Replacement (CJR) bundled payment model focused on knee and hip replacements, and cancel cardiac and other orthopedic bundled payment models that are scheduled to begin on January 1, 2018.

As a member of Congress and in his confirmation hearings as Secretary of the Department of Health and Human Services (HHS), Secretary Tom Price raised concerns about regulations issued by the Obama Administration to test the orthopedic and cardiac bundles payment models in so many geographic areas on a mandatory basis.

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CMS proposes changes to MACRA Quality Payment Program for 2018

The Center for Medicare and Medicaid Services (CMS) on June 30, 2017, published a proposed rule outlining changes for the 2018 performance year of the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA’s QPP includes the incentive payments for advanced alternative payment models (A-APMs) and the Merit-based Incentive Payment System (MIPS). Performance in 2018 will determine payment adjustments to clinicians that will be applied to their Medicare Part B payments in 2020.

The first performance year began January 1, 2017, for Part B payment adjustments in 2019.

MACRA repealed the sustainable growth rate (SGR) formula for updates to the Medicare Part B Physician Fee Schedule and sets payment updates for all years in the future. Through the QPP, the law is intended to link Medicare payment updates to quality and performance and drive the health care payment system across all payers away from fee-for-service reimbursement models.

Select key provisions of the proposed rule are highlighted below.

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CMS provides updates on Quality Payment Program and new episode payment models as MACRA pushes forward

In late December 2016, the Centers for Medicare and Medicaid Services (CMS) released additional guidance for implementing the significant law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as a follow-up to the Final Rule released in October 2016.

While the fate of other legislation such as the Affordable Care Act is in question, the implementation of MACRA continues to move forward as planned with bipartisan support.  The released guidance includes a number of updates to support providers transitioning to the Quality Payment Program (QPP) established by MACRA, including the 2017 quality measure performance benchmarks to be used in the Merit-based Incentive Payment System (MIPS) and the patient relationship categories and codes used to measure cost under MIPS.

Additionally, CMS finalized three new episode payment models with tracks which may be considered advanced Alternative Payment Models (APMs) for purposes of the QPP, as well as released additional information on the ACO Track 1+ model, which will qualify as an advanced APM in 2018.

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CMS locks in January 1, 2017 start date in final rule on new Medicare payment tracks under MACRA

The Centers for Medicare and Medicaid Services (CMS), on Friday, October 14, 2016, issued the heavily anticipated final rule on the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Together, CMS is referring to the new payment tracks through MIPS and Advanced APMs as the Quality Payment Program (QPP).

MACRA repealed the sustainable growth rate (SGR) formula for updates to the Medicare Physician Fee Schedule and sets payment updates for all years in the future. Through the QPP, the law is intended to link Medicare payment updates to quality and performance and drive the health care payment system across all payers away from fee-for-service reimbursement models.

The first performance period under MACRA will begin on January 1, 2017, and the first payment adjustments under the law will take effect for 2019.

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CMS provides clinicians flexibility under MACRA but retains 2017 start date for first performance period

Posted by Anne Phelps, Principal, US Health Care Regulatory Leader, Deloitte & Touche LLP and Daniel Esquibel, Deloitte Advisory Senior Manager, Deloitte & Touche LLP on September 9, 2016

In a blog post late Thursday, September 8, 2016, Centers for Medicare & Medicaid Services (CMS) Administrator Andy Slavitt announced two new options for participation in the Merit-based Incentive Payment System (MIPS) that are intended to give clinicians more flexibility to participate in the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Notably, the blog post states that the first performance period will still begin on January 1, 2017.

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