APM: What Providers Need to Know About Proposed Rules
With 2017 being the transition year for the Quality Payment Program (QPP), providers may wonder what they can expect in year two. The Centers for Medicare and Medicaid Services published an extensive document outlining proposed changes to both the Alternative Payment Models (APM) and the Merit-based Incentive Payment System (MIPS), and you'll note that CMS opted to keep a lot of the finalized policies from last year.
Still, there are changes coming, and some providers may be better positioned to enter Advanced APM status in 2018 than they were in the transition year. Successfully leveraging the programs to boost revenues depends heavily on practice ability to keep up with details and requirements, which makes consulting with TempDev a good idea for many practices. By working ahead of deadline dates, practices can shore up processes and ensure their EHR and workflows are viable under the updated rules. Here's a quick look at the QPP Proposed Rule for year two and why you might want to partner with TempDev to be successful.
More Providers are Likely to Qualify for Advanced APM Status
CMS has finalized some rulings and proposed minor changes to other rules, all of which are targeted to making it easier for practices to qualify for Advanced APM status. One of those changes is to extend the revenue-based nominal standard through 2020 instead of 2018. CMS is also proposing a change for Medical Home Models, which would adjust the nominal standard minimum risk to two percent of the average Part A and B revenues. This would apply to entities with less than 50 practicing clinicians unless the entity participated in Round 1 of CPC Plus.
What providers need to know is that these changes make it easier for some facilities to qualify for the quality programs with regard to the revenue requirements. However, even if you meet the revenue requirements, you still have to ensure quality and technical components are in line with Advanced APM status. TempDev can help you keep your eye on all the moving parts relevant to the programs.
2014 CEHRT Requirements Are Only Good through 2018
CMS extended the grandfathering of 2014 CERHT requirements through 2018, which is good news if you're still getting your software development and tech resources in order. What providers needs to know is that 2018 is going to come and go quickly, and EHR upgrades and implementations take time. They take even more time if you do everything in house, which is why working with TempDev is a good idea; outside resources help you identify and close the gaps in processes and support a faster-time-to-use on any EHR system or update your need to roll out.
The All-Payer Combo Makes it Easier to Qualify, but Harder to Quantify
Finally, CMS is still planning to implement the All-Payer Combination Option for performance year 2019 (for revenue impact in payment year 2021). CMS is also adding a Total Risk standard to this option, which would add an eight-percent revenue-based nominal amount standard that could be applied only when risk for APM Entities is defined solely in revenue terms.
What those changes boil down to is this: you must have a formal, efficient way of tracking and managing all your patients and payments, regardless of pay source, and that system must be fully operational by the beginning of 2019. By proactively capturing and managing your patient and payment data, you'll know exactly how you qualify for APM status and you can mitigate issues that put your patients, your qualifications or your revenue at risk.