- A follow-up investigation of Quality Payment Program (QPP) management by CMS conducted by the Office of Inspector General (OIG) yielded two recommendations to improve program implementation and integrity.
OIG first conducted a review of CMS’s management of QPP in 2016. During this initial review, OIG recommended CMS provide guidance and technical assistance to prepare clinicians to participate in the program and develop IT systems to support data reporting, scoring, and payment adjustment.
In the follow-up review, OIG determined CMS has taken significant steps to address the problems OIG identified in its 2016 investigation. OIG also interviewed CMS staff and reviewed internal CMS documents to find potential program vulnerabilities and identify emerging problems.
“With regard to IT, CMS appears on track to deploy the systems needed for data submission by January 1, 2018,” OIG reported. “It has added new content and functionality to the public website; deployed an IT product to make eligibility determinations; and tested, but not yet fully deployed, applications to support data submission and real-time scoring.”
OIG also stated CMS has conducted sufficient outreach, communicated eligibility information, issued sub-regulatory guidance, and established a Service Center to respond to clinician questions in an effort to improve guidance and technical assistance.
“CMS also awarded a variety of technical assistance contracts; however, contractors’ efforts to date have focused primarily on general education for a broad audience rather than specialized technical assistance to address practice-specific needs,” noted OIG.
After analyzing CMS-collected clinician feedback, OIG found that most clinicians are aware of QPP, but many remain uncertain about eligibility, data submission, and other aspects of the program.
Specifically, clinicians need assistance with determining the appropriate QPP track, selecting measures best suited to their practice, and submitting performance data to CMS.
To ensure clinicians can successfully fulfill QPP requirements, OIG urged CMS to ensure participating providers receive sufficient guidance and technical assistance. Otherwise, many clinicians may struggle to succeed under QPP or opt not to participate in the program at all.
“This is of particular concern for small practices and clinicians in rural or medically underserved areas, who may lack the resources to fully engage in the QPP without customized technical assistance to meet practice-specific needs,” clarified OIG.
OIG found CMS contractors have so far focused mostly on general QPP education initiatives, allotting fewer resources to more customized, practice-specific technical assistance efforts. This focus on overarching program concepts rather than specific requirements has left many clinicians in the dark about eligibility and scoring criteria.
“CMS needs to continue to assess progress and increase the proportion of contractors’ efforts devoted to specialized technical assistance to support high levels of clinician participation,” reported OIG.
In addition to the lack of practice-specific technical assistance, OIG also found CMS has not yet developed or implemented a comprehensive QPP integrity plan to deter instances of frauds or improper payment adjustments.
“Appropriate oversight—particularly to ensure the accuracy of clinician-submitted data—is critical to prevent improper QPP payment adjustments,” stated OIG.
“Although CMS included oversight provisions in the QPP final rule for 2017 and has initiated oversight planning, it still needs to clearly designate leadership responsibility for QPP program integrity and develop a plan to prevent and address fraud and improper payments,” they continued.
Implementing a QPP integrity plan will also help to reduce instances of fraud. Several healthcare organizations – including 21st Century Oncology – have recently come under fire following allegations of false meaningful use attestations used to acquire incentive payments and avoid downward payment adjustments.
“Safeguarding the validity of MIPS data and the accuracy of QPP payment adjustments is critical to ensure that these payments are based on clinicians’ actual performance,” stated OIG.