March 27, 2020

Weekly line: What providers need to know about CMS' recent changes to Medicare quality payment programs

Daily Briefing

    As providers shift their focus and resources toward combating the new coronavirus, the Trump administration recently signaled it's willing to put some of its larger health care priorities on the backburner to support physicians' response to the epidemic during this trying time.

    Public option vs. Medicare for All: What would they really mean for hospitals?

    What's changing—and what the changes mean for providers

    CMS on Sunday announced it is leveraging its extreme and uncontrollable circumstances policy exceptions and extending deadlines for certain reporting and data submission deadlines for several of Medicare's clinician, hospital, and post-acute care quality reporting programs, including the 1.2 million providers participating in Medicare's Quality Payment Program (QPP).

    Clinician-focused programs: For clinicians, CMS essentially is delaying 2019 data submission deadlines for QPP's Merit-based Incentive Payment System (MIPS) and Medicare Shared Savings Program (MSSP) ACOs. The data originally was scheduled to be due March 31, but the agency is extending that deadline to April 30.

    However, MIPS-eligible clinicians who don't submit 2019 data by April 30 will automatically qualify for the agency's extreme and uncontrollable circumstances policy exception. Those clinicians will receive neutral payment adjustments for the 2021 payment year.

    What this means for providers:

    1. MIPS-eligible clinicians and MSSP ACOs have more time to report their data. And specifically for MIPS-eligible clinicians, providers who are unable to submit data for the 2019 program year will not be penalized—which could affect potential bonuses under the program, as well. Because MIPS is budget neutral, fewer negative adjustments under the program means that positive adjustments also will be lower than CMS originally estimated.

    2. Providers who are in the process of deciding whether or not to submit data should assess their anticipated score. Providers should keep in mind that, for those who reach the exceptional performance threshold of 75 points, there is an additional $500 million bonus pool to fund positive adjustments that is not subject to budget neutrality.

    3. More changes could be on the horizon. CMS said it is still "evaluating options for providing relief around participation and data submission for 2020," so clinicians and ACOs should keep in mind that their reporting requirements and deadlines for 2020 might change, as well.

    Hospital-focused programs: For hospitals, CMS again is giving providers the option of whether to submit certain 2019 data, and also is giving providers a complete reprieve from reporting certain 2020 data for the following programs:

    • The Ambulatory Surgical Center Quality Reporting Program;
    • The CrownWeb National End-Stage Renal Disease (ESRD) Patient Registry and Quality Measure Reporting System;
    • The ESRD Quality Incentive Program;
    • The Hospital-Acquired Condition Reduction Program;
    • The Hospital Inpatient Quality Reporting Program;
    • The Hospital Outpatient Quality Reporting Program;
    • The Hospital Readmissions Reduction Program;
    • The Hospital Value-Based Purchasing Program;
    • The Inpatient Psychiatric Facility Quality Reporting Program;
    • The PPS-Exempt Cancer Hospital Quality Reporting Program; and
    • The Promoting Interoperability (PI) Program for Eligible Hospitals and Critical Access Hospitals.

    Providers participating in those programs can choose whether to submit data on the last quarter (Q4) of 2019. If participants choose to submit the data, CMS will use it when calculating their 2019 performance scores and any corresponding payment adjustments. If participants choose not to submit the data, CMS will calculate their 2019 performance scores and any corresponding payment adjustments based on available data from the first three quarters of the year.

    For 2020, CMS said program participants do not have to submit any data on the first two quarters of this year. CMS won't be using any submitted data on Jan. 1 through June 30 to calculate 2020 performance scores or payment adjustments—with two exceptions: CMS will use any data that providers choose to submit on the first quarter of this year under the Hospital-Acquired Condition Reduction Program and the Hospital Value-Based Purchasing Program to calculate performance scores where appropriate, though submission isn't required.

    What this means for providers:

    1. Providers who have yet to submit 2019 data should consider now if they want to submit the optional Q4 2019 data. In weighing that decision, providers should bear in mind that Q4 data is not only a component of performance and payment in programs like the Hospital Readmissions Reduction Program, the Hospital-Acquired Condition Reduction Program, and the Hospital Value-Based Purchasing Program for upcoming payment adjustments, the data also factors into payment adjustments for future years.

    2. Some programs' deadlines for submitting 2019 data already have passed. For example, the last day for hospitals to submit 2019 data under the PI program was March 2. In addition, CMS so far hasn't indicated any specific changes for 2020 PI reporting requirements.

    3. CMS' decision to waive the 2020 data reporting for the first two quarters of this year should free up providers to be able to shift resources to more pressing matters and away from tracking and submitting quality data for the affected programs.

    Post-acute-care-focused programs: CMS made similar changes on the post-acute-care level for:

    • The Home Health Quality Reporting Program;
    • The Hospice Quality Reporting Program;
    • The Inpatient Rehabilitation Facility Quality Reporting Program;
    • The Long Term Care Hospital Quality Reporting Program;
    • The Skilled Nursing Facility Quality Reporting Program; and
    • The Skilled Nursing Facility Value-Based Purchasing Program.

    Providers participating in the post-acute care programs also will be able to choose whether to submit Q4 2019 data. If participants choose to submit the data, CMS will use it when calculating their 2019 performance scores and any corresponding payment adjustments.

    CMS said 2020 program participants do not have to submit any data on the first two quarters of this year, and affected providers do not have to submit data from the Home Health and Hospice Consumer Assessment of Healthcare Providers and Systems survey from the first three quarters of this year.

    CMS won't use any of that data to calculate 2020 performance scores or payment adjustments, nor will it use qualifying claims from the Skilled Nursing Facility Value-Based Purchasing Program's claims-based 30-Day All-Cause Readmission Measure from first two quarters of this year when calculating performance scores or payment adjustments.

    What this means for providers:

    1. Since CMS won't be using any of that data when calculating performance scores and corresponding payment adjustments, providers can shift resources to more pressing matters instead of tracking and submitting the data. However, as noted above, providers who opt out of submitting their optional data should bear in mind the omitted data normally would be used to calculate performance and payments in future years.

    More changes to come?

    While the Trump administration is willing to temporarily suspend its focus on value-based payment programs during this public health emergency, CMS hasn't indicated that it won't resume that focus once the epidemic is under control.

    As far as we know right now, CMS has no plans to cancel the affected value-based payment programs, so providers should expect that data reporting and any associated performance scoring and payment adjustments will continue in 2021, 2022, and beyond.

    That being said, providers might see additional changes in the shorter term, as CMS said it will continue to monitor the epidemic and assess opportunities to provide relief to clinicians and facilities so they can focus on treating patients.

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