Life Science Compliance Update

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February 09, 2017

CMS Missing Critical QPP Infrastructure

Money hitn_4

The United States Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently published a report, “Early Implementation Review: CMS’s Management of the Quality Payment Program.” The report can be summed up by noting that CMS has made significant progress toward implementing the Quality Payment Program (QPP), but there are two vulnerabilities that are critical for CMS to address in 2017, (1) providing sufficient guidance and technical assistance to ensure that clinicians are ready to participate in the QPP, and (2) developing IT systems to support data reporting, scoring, and payment adjustment.

What the OIG Found

OIG identified CMS’ five key management priorities regarding the agency’s planning and early implementation of the QPP. Early on, CMS staff determined that clinicians’ acceptance of the QPP, and readiness to participate in it, would be the most critical factor to ensuring the program’s success. This focus also worked to inform CMS’ decisionmaking regarding its other management priorities, including: adopting integrated internal business practices to accommodate a flexible, user-centric approach; developing information technology (IT) systems that support and streamline clinician participation; developing flexible and transparent MIPS policies; and facilitating participation in Advanced APMs.

OIG notes that “CMS has built a promising foundation” for managing clinicians’ transition to MACRA, but the agency hasn't built the infrastructure that will receive doctor-submitted data, figure out their MIPS scores, and adjust their payments. Given that data submission begins in 2017, the lack of such infrastructure is a bit of a problem, particularly given the agency's historical issues with respect to large-scale IT projects (i.e., its Open Payments or sites).

“Early on, CMS staff decided that clinicians' acceptance of the Quality Payment Program, and readiness to participant in it, would be the most critical factor to ensuring the program's success,” the OIG said in the report. However, the report also cautions that the CMS must continue to provide assistance to clinicians so they can comply with the Medicare Access and CHIP Reauthorization Act, which was issued in October

The OIG said the CMS' technical assistance and training efforts for physicians “must quickly be ramped up to full-scale.” The OIG specifically highlights the importance of ensuring small and rural practices have all the tools they need to comply with MACRA. 

The report also cites a lack of outreach to providers as a problem, "If providers lack the knowledge, tools, or skills to participate, they will struggle to meet the QPP reporting requirements."

In response to the report, the CMS said a variety of technical assistance efforts are underway and the agency is working on optimizing IT systems. The agency also has a backup plan: it's got data-submission infrastructure built for the EHR, PQRS and value-based payments programs. That infrastructure should, to some degree, solve the potential data-submission problem, if it materializes.

The CMS staff also noted that they drew on failures from the rollout of to launch MACRA. One CMS official said, “ was a really low moment for the agency, but it was a learning moment, which allowed us to learn the lessons of how to build new muscles (from the turnaround of) and apply them to the MACRA program.” 

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