The Office of Inspector General (OIG) conducted an early implementation review of CMS’s management of the Quality Payment Program (QPP) to pinpoint milestones, priorities, and challenges related to QPP implementation and overall payment reforms.
In formulating their report, OIG conducted interviews with staff members. OIG also conducted an extensive review of both internal CMS documents and publicly accessible documents.
In the review, OIG identified CMS’s key management priorities in planning and implementing the QPP.
The QPP was created in response to the Medicare Access and CHIP Reauthorization Act of 2015, which enforces clinician payment reforms geared toward improving the quality and value of patient care.
These reforms comprise the QPP, which aims to more efficiently and accurately calculate Medicare’s compensation for clinicians.
On October 14, 2016, CMS issued its final regulations for measuring, reporting, and scoring the value and quality of care. The QPP measures clinicians’ compensation per calendar year. Clinicians may participate in either the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs).
In the report, OIG indicated that clinician’s acceptance of QPP and willingness to participate in the program would be instrumental in ensuring the program’s success.
With clinicians as the focal point, OIG outlined several priorities including “adopting integrated internal business practices to accommodate a flexible, user-centric approach,” “developing flexible and transparent MIPS policies,” and “facilitating participation in Advanced APMs” according to the Early Implementation Review.
While CMS has made progress toward implementing the QPP, two significant obstacles remain.
CMS still needs to provide sufficient guidance and technical assistance for clinicians participating in the QPP and develop IT systems to support data reporting, scoring, and payment adjustment. These vulnerabilities inhibit the full implementation of the program.
Because CMS anticipates facing resistance from clinicians unwilling to adhere to strict QPP policies, encouraging clinicians to participate in the program and communicating its benefits will be instrumental in bolstering the program’s success.
In the future, OIG urges CMS to “continue clinician engagement and outreach activities” so as to maintain clinician participation. OIG views clinician’s willingness to engage in the program as “essential to CMS’s efforts to ensure that providers have the information and tools they need to meet the challenges of the QPP.”
OIG plans to administer guidance to Medicare clinicians to help them understand the QPP, use the transition year to familiarize themselves with the program, select the QPP option that best suits their specific practice, and use QPP feedback to improve quality of care.
Capable IT systems are also crucial to the program’s success in supporting the QPP.
OIG points out IT systems are necessary for clinicians to report QPP data to CMS accurately.
With this reliable, secure information available, CMS will then be expected to validate the data and calculate MIPS final scores, provide performance feedback information to clinicians, and adjust payments based on clinicians participation in the program.
CMS reviewed OIG’s response to their QPP implementation and “reiterated its goal of providing patient-centered, high-quality care for Medicare beneficiaries.” CMS also expressed their consideration for small, rural practices that may face distinct challenges. CMS intends to accommodate these practices’ particular needs accordingly.
In terms of the two vulnerabilities OIG identified in the report, CMS stated it is “committed to continuing to engage with clinicians and provide them with assistance, and to optimize backend IT systems support.”
Despite these two areas in need of improvement, OIG ultimately concluded that CMS has made “significant progress in implementing the QPP.”