Executive Summary
On December 18, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released a draft Quality Measure Development Plan (“Draft Plan”) to serve as a strategic framework for the future of clinician quality measure development for the transition to new Merit-Based Incentive Payment System (“MIPS”) and alternative payment models (“APMs”).1 The Draft Plan was developed pursuant to the passage of the Medicare Access and Children’s Health Insurance Program Reauthorization Act of 2015 (“MACRA”), which required the Secretary of Health and Human Services to develop a draft plan for the development of quality measures by January 1, 2016 for application under certain applicable provisions related to MIPS and APMs. MACRA supports the ongoing transformation of health care delivery by furthering the development of new Medicare payment and delivery models for physicians and other clinicians.
Details of the Draft Plan
The purpose of the framework prescribed by the Draft Plan is to:
- Address how measures used by private payors and integrated delivery systems could be incorporated into Medicare payments;
- Describe how coordination across organizations developing such measures could occur; and
- Evaluate how best practices and clinical practice guidelines should be used in the development of quality measures.
Beginning in 2019, the Draft Plan indicates CMS will apply a positive, negative or neutral payment adjustment to each MIPS eligible professional based on a composite performance score across four performance categories, including: (1) quality; (2) resource use; (3) clinical practice improvement activities; and (4) meaningful use of certified electronic health record technology. Measures for use in the quality performance category are the focus of the Draft Plan. The Draft Plan indicates that MIPS will build upon existing quality measure sets from the Physician Quality Reporting System, Value-Based Payment Modifier and meaningful use. Notably, the Draft Plan is general in nature and does not specifically identify how measures will be selected.
Practical Takeaway
CMS is soliciting comments to the Draft Plan from the public, including health care providers, through March 1, 2016. After reviewing the public commentary, CMS will issue a final version of the Draft Plan on the CMS.gov website by May 1, 2016.If you are interested in submitting a comment or would like additional information about the Draft Plan or MACRA, please contact:
- Joe Wolfe at 414.721.0482 or jwolfe@hallrender.com;
- Ammon Fillmore at 317.977.1492 or afillmore@hallrender.com;
- Lauren Hulls at 317.977.1467 or lhulls@hallrender.com;
- Janice Pascuzzi at 317.429.3648 or jpascuzzi@hallrender.com; or
- Your regular Hall Render attorney.
Please visit the Hall Render Blog at http://blogs.hallrender.com/ or click here to sign up to receive Hall Render alerts on topics related to here care law.1 For a full copy of the Plan, click here.
