As the Quality Payment Program Year 2 moves forward, clinicians and practitioners must be prepared for the changes that have already occurred while you prepare for the changes that will occur. Keeping track of everything can be a challenge. Here’s a quick checklist to help you determine where you are for this year’s progress:
- Check each category’s time frame. Resource Use (Cost) and Quality are both judged on the 12-month period. Clinical Practice Improvement Activities and Promoting Interoperability (formerly Advancing Care Information) are reviewed on a continuous 90-day period.
- Ensure compliance with electronic health record programs. You are allowed to use a 2014 or 2015 Certified Electronic Health Record Technology program this year. If you have a 2015 edition, you will receive a bonus this year. You must upgrade to a 2015 CEHRT or higher by the end of this year.
- Verify Promoting Interoperability (or ACI) measures and the required workflow for them. You have to determine if your practice should report non-transition measures or ACI transition measures. This includes practices that are submitting non-transition measures. You should also validate that programs and interfaces are installed and set up in a way that meets the appropriate requirements. Make sure you configure any HQM programs when they are available to you.
- Review each category’s weight. This year, the weight each category holds changed. Cost currently accounts for 10 percent, Promoting Interoperability accounts for 25 percent, Clinical Practice Improvement Activities accounts for 15 percent, and Quality accounts for 50 percent.
- File your reports. For Year 2, you only need to report for three out of four categories. You don’t need to worry about Cost since that information is taken from the claims you submit. You can only use one submission mechanism per category when you report.
- Determine your practice or practitioner status. Smaller practices this year are classified as those who have 15 or less National Provider Identifiers per Tax Identification Number. This includes any advanced practitioners so be sure to include them.
- Figure out if you qualify as a low-volume practice. The criteria this year is either fewer than 200 Part B beneficiaries or less than $90,000 in Part B allowable charges. If you meet either of those, you qualify as a low-volume practice.
- Look into Advanced APMs. If you qualify for one of these, you might be able to qualify for incentive payments. These can start or end in the middle of a year to make it easier to qualify for them. Some practices won’t have an Advanced APM so ensure you are reporting in the appropriate manner whether you have them or not. Keep in mind some APM’s (CPC for example) need to upgrade by December 31, 2018.
- Find out how many points you have. If you want to avoid a 4-percent cut in 2019 fees, you need to earn 15 points for this year. The additional performance threshold is 70 points, so you can aim for this if you want to be classified as an exceptional performance provider.
- Determine if you are eligible for bonus points. Small practices can receive 5 bonus points and clinicians who treat complex patients can also receive 5 bonus points. These are added to the final score for the year. Small practices can receive 3 points for data in the Quality category even if they don’t meet the completeness requirements.
Some of these points aren’t factors for some practitioners, so it is important to determine if you qualify for any special programs. For example, areas that were impacted by Hurricane Maria, Harvey, or Irma have some exceptions. Practitioners in these areas won’t have to worry about Quality, Improvement Activities, or Advancing Care Information since these are weighted at 0 percent for qualifying practices. This means that Cost is the only factor that is going to be considered for compliance.
Another factor that might impact some individuals and small practices is the possibility of using Virtual Groups. This gives them a chance to join with other individuals or practices to combine efforts to meet the compliance requirements and benchmarks for this year. This is a fully optional program that you have to elect to join.