The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established the Quality Payment Program (QPP). QPP transitions Medicare payment away from fee-for-service to pay-for-performance, emphasizing quality care. The program represents a significant change in the way all physicians, including radiation oncologists, are paid by Medicare.
Participation in the QPP is through one of two pathways:
MIPS combines and replaces the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM) and Medicare EHR Incentive (Meaningful Use) programs into one comprehensive program. The MIPS program involves four performance categories: Quality, Advancing Care Information (ACI), Improvement Activities (IA) and Cost.
To date there have been two program years with varying requirements.
As with previous Medicare programs, there is a program cycle consisting of performance measurement, data submission, feedback, and payment adjustments.
The 2017 performance period opened January 1, 2017, and closed December 31, 2017. The 2018 performance cycle runs from January 1, 2018, to December 31, 2018. During each of these performance periods, physicians or groups record data for the elements of each MIPS category in which they participate. If the practice is participating in an Advanced APM, such as the two-sided risk version of the Oncology Care Model (OCM), then physicians or groups can join that model during the year and do not need to report under MIPS.
To potentially earn a positive payment adjustment under MIPS, physicians or groups send in data on care provided and the elements of each MIPS performance category to CMS by the deadline, March 31 following the close of the performance year. For the 2018 performance year, data must be sent to CMS by March 31, 2019. For practices participating in an Advanced APM, such as the OCM (two-sided risk), physicians or groups send quality data through the Advanced APM to CMS.
CMS will provide feedback about performance based on the submitted data in the year following the performance year.
Physicians or groups may earn a positive MIPS payment adjustment based on submitted data two years after the performance period. If physicians or groups participate in an Advanced APM, then they may earn a 5 percent incentive payment two years after the performance year.
2017 performance period began
Last chance to start 90-day reporting period
2017 performance period ended
2018 performance period began
Deadline to submit 2017 performance data
CMS feedback provided to clinicians for 2017 performance data
Last change to start a 90-day reporting period
2018 performance period ends
2019 performance period begins
Deadline to submit 2018 performance data
2017 payment adjustments implemented (+/- 4 percent)
CMS feedback provided to clinicians for 2018 performance data
2019 performance period ends
2020 performance period begins
Deadline to submit 2019 performance data
2018 payment adjustments implemented (+/- 5 percent)
CMS feedback provided to clinicians for 2019 performance data