Pick Your Pace Under MACRA
The ACR Commission on Economics stands ready to provide tools for radiologists to achieve Quality Payment Program Success.
The Medicare & Chip Reauthorization Act (MACRA), now referred to as the Quality Payment Program (QPP), will impact radiology payments beginning in January 2019. But the performance period for 2019 started on January 1, 2017. Well, sort of.
Last September, CMS announced that clinicians will be able to "Pick Your Pace" regarding participation in 2017. There are participation options ranging from "do nothing" to recognition as an "exceptional performer." Do radiologists have the ability and tools to become recognized as exceptional performers and receive the maximum bonus? To help answer this question, this column will explore the different levels of participation and what level of performance each requires.
How will we be scored under the QPP? Almost all radiologists will report through the Merit-Based Incentive Payment System (MIPS), which consists of four separate performance categories: Quality Cost, Advancing Care Information (ACI), and Improvement Activities (IA). Based on our performance in each category, we will receive a cumulative score from 0 to 100. This score will be compared to a national "performance threshold" that will determine whether we receive a bonus, penalty, or no adjustment at all.
The four levels of participation in MIPS for 2017 are as follows:
1. Do nothing and receive the maximum penalty of four percent in 2019.
2. Those who wish to "test the QPP" may report the bare minimum be reporting only one Quality or IA measure on one patient. This yields no penalty, but also no bonus, resulting in a neutral adjustment overall.
3. At a higher level of participation, those of us who report for "part of the calendar year" (90 consecutive days), will avoid penalty and may receive a smaller bonus than the maximum four percent.
4. On the highest end of the spectrum, those who maximally report have the potential to not only receive the baseline bonus of four percent; they also have the potential to receive additional bonus payments reserved for exceptional performers.
Regardless of the payment adjustment, our score and performance will be publicly available on the Physician Compare website. There is no reason for practices to do nothing and endure the maximal penalty, as the "test the QPP" option is relatively easy to achieve. In fact, I advise that all radiologists work to become exceptional performers and I present a path to make that happen within each of the four performance categories.
First, all physicians are exempt from performance scoring in the Cost category in 2017, and most radiologists will likely be exempt from the ACI category in 2017. Therefore, our score in one year largely depends on performance in quality (85 percent) and IA (15 percent). My recommendations are as follows:
Quality: To achieve the highest score possible, report through a Qualified Clinical Data Registry (QCDR) such as the ACR National Radiology Data Registry® and report on high priority measures.
IA: The requirements for IA depend on whether CMS identifies us as patient-facing or non patient-facing. The required number and type of IA could be anywhere from one to four activities, depending on whether we choose high- or medium-weighted activities. For example, individuals or groups considered non-patient facing need only attest to one highly weighted activity, such as R-SCAN™. R-SCAN enables radiology practice and their referring physicians to implement clinical decision support tools in advance of the anticipated 2018 mandate.
I believe radiology is well positioned to be a specialty of "exceptional performers" during 2017 performance period and in years to come. CMS has been forthright that 2017 and 2018 are transitional performance years under the QPP, so we can get to the top of the scoring system while other physicians participate at lower levels. But doing so will require planning and process improvement within our practices, and the timeline is short. The Commission on Economics stands ready to help enable success under the QPP for all radiology.
By Ezequiel Silva III, MD, FACR, Chair