September 16, 2016

CMS Reduces Risks for MACRA Reporting Penalties

The Centers for Medicare & Medicaid Services (CMS) is offering radiologists and other physicians several ways to meet their initial data reporting requirements to reduce the risk of financial penalties from participation in the new Quality Payment Program (QPP) created by the Medical Access and CHIP Reauthorization Act of 2015 (MACRA).

In a Sept. 8 blog posting, CMS Acting Administrator Andrew Slavitt, announced CMS will be flexible in its implementation of rules governing in the proposed Jan. 1, 2017 start date for performance data reporting by physicians under QPP. The final MACRA rule will be published on about Nov. 1.

Many clinicians have expressed concern about the short lead time between the probable publication date for the MACRA final rule and the start of required data reporting just two months later. During that time, Medicare practitioners must digest new payment system requirements, including mandatory data disclosure rules for their participation in either the Merit-based Incentive Payment System (MIPS) or an advanced alternative payment model (APM).

CMS is not planning to delay QPP’s start date, Slavitt noted, but eligible physicians and other clinicians will have multiple options for participation in 2017. He assured them that they can avoid or minimize a possible negative payment adjustment or qualify for a positive payment adjustment in 2019 by following one of four “Pick Your Pace” avenues for participation:

  • Clinicians could test the quality payment program. “With this option, as long as you submit some data to the Quality Payment Program, including data from after Jan. 1, 2017, you will avoid a negative payment adjustment,” Slavitt wrote. The blog post does not describe which categories of data must be submitted or how much data will be required to meet the “submit some data” threshold.
  • Clinicians could participate for part of the calendar year and qualify for a small positive payment adjustment.
  • Clinicians could participate for the full calendar year and earn a positive payment adjustment.
  • Clinicians who participate in advanced alternative payment models, such as a Track 2 or 3 Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO), will be eligible for five percent incentive payments.

CMS notes these options and other supporting details will be described fully in the MIPS/APMs final rule. The “Pick Your Pace” avenues were also described in a Sept. 12 Department of Health and Human Services Regulatory Review.

ACR members can direct their questions about QPP implementation to Pamela Kassing at