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Friday, December 2, 2016

University of Colorado clinic wins 2016 FPM Award for Practice Improvement

The University of Colorado School of Medicine Department of Family Medicine has won this year’s Family Practice Management (FPM) Award for Practice Improvement. The department was presented with the award Friday during the Society of Teachers of Family Medicine Conference on Practice Improvement being held in Newport Beach, Calif.

FPM Editorial Advisory Board member John Bachman, MD, presented the award to the department’s medical director, Corey Lyon, DO.

The program was recognized for its success in implementing a team-based model to address access issues, poor outcomes, and burnout. Implementation included increasing provider support with additional medical assistants and support staff, and expanding their roles.

“Culture will eat strategy for breakfast, lunch, dinner, and a midnight snack,” Lyon said. “We had to move beyond the culture of ‘I can’t do that. That’s not how we do it.’”

After one year, monthly visits increased 25.6 percent. Staff costs per visit were unchanged, but monthly charges increased 20 percent. Additionally, provider self-reported burnout was reduced by half.

CMS extends deadline to review value modifier and PQRS results

The Centers for Medicare & Medicaid Services (CMS) has extended until Dec. 7 the deadline for family physicians and others to request an informal review of their value modifier and Physician Quality Reporting System (PQRS) results, which will otherwise impact Medicare physician payments in 2017.

CMS released the 2015 annual Quality and Resource Use Reports (QRURs) on Sept. 26. The 2015 annual QRURs show how physician groups and solo practitioners performed in 2015 on the quality and cost measures used to calculate the 2017 Value Modifier as well as their 2017 Value Modifier payment adjustment.

You can access and review your 2015 annual QRUR now to determine whether you are subject to the 2017 Value Modifier payment adjustment. You will need an Enterprise Identity Management (EIDM) account with the appropriate role to obtain your 2015 annual QRUR. The CMS web site contains instructions for signing up for the appropriate role in EIDM and instructions for accessing the QRUR. Also available on this webpage is a streamlined instructional guide for accessing the QRUR titled “Quick Access Guide for the 2015 Annual QRURs and Tables.”

Physician groups or solo practitioners may request an informal review of perceived errors in their 2017 Value Modifier calculation during the informal review period, which now expires on Dec. 7 at 11:59 p.m. (EST). Additional information about the 2015 Annual QRURs and how to request an informal review is available on CMS’s 2015 QRUR and 2017 Value Modifier webpage.

In 2017, CMS will apply a downward payment adjustment to those who did not satisfactorily report under the Physician Quality Reporting System (PQRS) in 2015.

If you have any questions regarding the status of your 2015 PQRS reporting or are concerned about potentially receiving the PQRS downward payment adjustment in 2017, you can also submit an informal review request for that and ask CMS to investigate your payment adjustment determination. However, again, you must do so by Dec. 7. CMS will be in contact with every individual eligible professional or PQRS group practice that submits a request for an informal review of their 2015 PQRS data and notify them via email of a final decision within 90 days of the original request for an informal review. All CMS decisions will be final, and there will be no further review.

Follow these steps to submit an informal review request:
1.    Go to the Quality Reporting Communication Support Page (CSP).
2.    In the upper left-hand corner of the page, under “Related Links,” select “Communication Support Page.”
3.    Select “Informal Review Request.”
4.    Select “PQRS Informal Review.”
5.    A new page will open.
6.    Enter Billing/Primary Taxpayer Identification Number (TIN), Individual Rendering National Provider Identifier (NPI), OR Practice Site ID # and select “submit.”

Complete the mandatory fields in the online form, including the appropriate justification for the request to be deemed valid. Failure to complete the form in full will result in the inability to have the informal review request analyzed. CMS or the QualityNet Help Desk may contact you for additional information if necessary. Please see the PQRS informal review fact sheet for more information.

Additionally, 2015 PQRS feedback reports can be accessed on the CMS Enterprise Portal using an EIDM account. For details on how to obtain your report, please see the “Quick Reference Guide for Accessing 2015 PQRS Feedback Reports.” For information on understanding your report, please see the “2015 PQRS Feedback Report User Guide.” Both guides are on the PQRS Analysis and Payment webpage on the CMS web site.

For More Help:
•    For additional assistance regarding EIDM or to ask questions about the informal review process, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715- 6222) from 7:00 a.m. to 7:00 p.m. Central Time, Monday through Friday, or via email at qnetsupport@hcqis.org. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in e-mail inquiries to the QualityNet Help Desk.
•    For additional assistance regarding the QRUR or the Value Modifier, contact the Physician Value Help Desk at pvhelpdesk@cms.hhs.gov or 888-734-6433 (select option 3).

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Monday, November 28, 2016

New code required in 2017 for telehealth services

Beginning Jan. 1, the Centers for Medicare & Medicaid Services (CMS) is creating a new place of service (POS) code for physicians who provide telehealth services from a distant site. POS code 02 is described as “The location where health services and health related services are provided or received, through telecommunication technology.”

Under HIPAA, non-medical code sets, such as POS, are paid based on what code set was in effect on the date of the transaction, not the date of service. So even if the date of service was in 2016, if you initiate the claim on or after Jan. 1, you should use the new POS code.

Note that you must still use modifiers GT (via interactive audio and video telecommunications systems) and GQ (via an asynchronous telecommunications system) when billing Medicare for telehealth services. If you bill POS code 02 but without the GT or GQ modifier, your Medicare administrative contractor (MAC) will deny the service. Your MAC will also deny the service if you bill for telehealth services with modifiers GT or GQ but without POS code 02.

CMS has provided additional information on this change through the Medicare Learning Network.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, November 15, 2016

New influenza vaccine code delayed until Jan. 1

If you are dispensing influenza vaccines under a new CPT code this fall, the Centers for Medicare & Medicaid Services (CMS) is suggesting that you do not send those claims in for payment right away.

This summer, CMS was scheduled to accept a new CPT code for influenza vaccine. The code, 90674, describes “Influenza virus vaccine, quadrivalent (ccIIV4), derived from cell cultures, subunit, preservative and antibiotic free, 0.5 mL dosage, for intramuscular use.” The CPT Editorial Panel accepted the code at its February meeting, and it will appear in the 2017 CPT book. CMS previously disclosed a payment allowance of $22.936 for code 90674, beginning for services provided on or after Aug. 1.

But CMS recently announced that Medicare claims processing systems will not be able to accept code 90674 until Jan. 1.

In the meantime, CMS advises that you hold claims containing that code until then. Also, if you bill institutional claims, CMS says that code 90674 will be implemented on Feb. 20.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, November 10, 2016

New pay increases in the 2017 Medicare physician fee schedule

The Centers for Medicare & Medicaid Services (CMS) has released its final rule on the 2017 Medicare physician fee schedule. Some of the several increases for care management services in 2017 will interest family physicians. For example, CMS next year will begin paying for:

• Non-face-to-face prolonged evaluation and management services

• Comprehensive assessment and care planning for patients with cognitive impairment

• Primary care practices to use interprofessional care management resources to treat behavioral health conditions

• Chronic care management (CCM) for patients with more complex conditions

In addition, CMS is trying to encourage more practices to offer and bill for CCM services by reducing the administrative burden associated with those codes.

CMS also will revalue existing codes describing face-to-face prolonged services. For 2017, CMS has set the Medicare conversion factor at $35.8887, which is slightly higher than the 2016 conversion factor of $35.8043. CMS expects that the provisions of the final rule will generate an estimated 1 percent increase in Medicare allowed charges for family physicians.

CMS has provided additional information in a fact sheet on the final rule.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Wednesday, November 2, 2016

How to avoid E/M errors and denials

The Centers for Medicare & Medicaid Services (CMS) says approximately 15 percent of evaluation and management (E/M) services are improperly paid and accounted for 9.3 percent of the overall Medicare fee-for-service improper payment rate in 2014. To help you avoid improper payment of your E/M claims and prevent payment denials, CMS has released a new fact sheet of compliance tips for E/M services.

According to the fact sheet, E/M claims are typically denied for two reasons: incorrect coding, such as the code not matching the documentation, and insufficient documentation, which can include a lack of a physician signature or no record of the extent and amount of time spent in counseling and/or coordination of care when it is used to qualify for a particular level of E/M service.

To prevent your E/M claims being denied, CMS recommends a number of strategies. First, in addition to the individual requirements for billing a selected E/M code, you should also consider whether the service is “reasonable and necessary.” For example, while it is possible to provide and document a level 5 office visit for a patient with a common cold and no comorbidities, it is unlikely that anyone would consider that level of service reasonable and necessary under those circumstances.

Another strategy is to remember the following key variables when selecting codes for E/M services:
•    Patient type (new or established)
•    Setting/place of service
•    The level of service provided based on the extent of the history, the extent of the examination, and the complexity of the medical decision making (i.e., the number and type of the key components performed)

Finally, the fact sheet emphasizes the need to obtain the necessary physician/non-physician provider signatures. You can find links to additional CMS resources and references at the end of the fact sheet.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Monday, October 31, 2016

Comprehensive Primary Care Plus program reopening to practices

Practices that missed the application deadline for the Comprehensive Primary Care Plus (CPC+) program will have another opportunity to apply next year.

The Centers for Medicare & Medicaid Services (CMS) recently announced it was reopening CPC+ applications for both payers and practices. Delays in the initial payer application process this summer shrunk the two-month practice application window by two weeks. Many practices felt this was not sufficient time to evaluate the program and determine if the added payment associated with CPC+ would support the amount of work necessary to comply with the program. 

In addition, at that time only one region in the original Comprehensive Primary Care initiative had achieved shared savings, which led some to believe it was not a successful program. On Oct. 17, CMS announced that four of the seven participating regions experienced net savings for 2015, the program’s second performance year.

The CPC+ program is one of the payment models recognized as an Advanced Alternative Payment Model (APM) in the final rule of the Quality Payment Program (QPP), part of the Medicare Access and CHIP Reauthorization Act. Participation in an Advanced APM offers physicians the opportunity to receive a 5 percent bonus payment.

CMS has not yet provided additional details on next year’s reopening of the CPC+ application process. In the meantime, you can learn more about the CPC+ application requirements by reviewing the original Request for Applications.

Kristen A. Stine, MSOD, Practice Transformation Strategist at the American Academy of Family Physicians

Friday, October 21, 2016

Some tips on MIPS included in the final MACRA rule

By now, you may have seen that the Centers for Medicare & Medicaid Services (CMS) has released a final rule that implements the Medicare Quality Payment Program (QPP) called for in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Most of this regulation is final and effective Jan. 1, but CMS seeks comments on some sections.

Meanwhile, here are some highlights for the Merit-based Incentive Payment System (MIPS) portion of the rule:

•    Eligible clinicians only need to score three points and report as little as one measure to avoid a negative payment adjustment in 2019. Eligible clinicians who achieve a final score of 70 or higher will be eligible for the exceptional performance adjustment, funded from a pool of $500 million.
•    Eligible clinicians only need to report for a minimum of 90 consecutive days in 2017 to be potentially eligible for a small upward payment adjustment in 2019, which means you can start reporting as late as Oct. 2, 2017.
•    CMS is decreasing the number of measures eligible clinicians must report.
•    CMS estimates that more than 90 percent of eligible clinicians will receive a positive or neutral payment adjustment in 2019.

Although CMS is still not offering small practices a “virtual group” option under MIPS, there was good news for these physicians. For instance, CMS is excluding more small practices from being subject to MIPS by raising the “low-volume threshold” for exclusion to be $30,000 or less in Medicare Part B allowed charges and 100 or fewer Medicare patients. CMS also estimates that at least 80 percent of solo practices and groups with nine or fewer clinicians will receive either a positive or no MIPS payment adjustment in 2019.

To accompany the final rule and provide more information, CMS also launched a new QPP website and issued an executive summary, press release, blog post from Acting CMS Administrator Andy Slavitt, and fact sheet about the regulation. A family medicine perspective on the final rule is also available.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Tuesday, October 11, 2016

New limited English proficiency rule to start Oct. 17

Sometimes, “getting paid” means implementing regulations as cheaply as possible without running afoul of the law. Such is the case with a federal rule that goes into effect next week.

Beginning Oct. 17, the U.S. Department of Health and Human Services (HHS) will require most physician practices to notify patients with limited English proficiency (LEP) of their freedom from discrimination and of the availability of language assistance services. This rule applies to all health programs or activities that receive funding from or are administered by HHS and the health insurance marketplaces as well as all plans offered by issuers that participate in those marketplaces. For instance, if you receive Medicaid payments or a “meaningful use” incentive payment, this rule applies to you. However, if your practice’s only source of federal funds is through Medicare Part B, then this rule does not apply to you.

To comply with the rule, your practice must ensure “meaningful access” for those with LEP by adhering to the following requirements:

•    You must post a notice of nondiscrimination in English and may combine the content of the notice with other notices required under other federal laws.
•    You must post taglines written in the top 15 languages in the state where your practice does business indicating that language assistance is available. HHS has determined the top 15 languages for each state. Ideally, the language of the tagline should be in the language to which it refers; HHS has translated resources on its website.

You must post the notices in a sufficiently prominent and noticeable place in your office, and the rule requires that you post the language assistance taglines on all “significant publications or communications.” This means items that would result in substantial consequences if the patient did not understand (e.g., notice of a treatment plan or a termination of coverage). If the publication or communication is electronic, it must have a link to the notice of nondiscrimination and 15 taglines on the bottom. If it is paper, the publication must have the statement of nondiscrimination and taglines, unless it is something small, like a postcard. In those cases, it only needs the statement of nondiscrimination and the tagline in the top two languages. The notice of nondiscrimination and top 15 taglines should also be at the bottom of your website.

If you have not already done so, now would be a good time to develop a plan to address the needs of patients with LEP. Ideally, the plan should include all languages frequently used in the practice, even if they are not included in the top 15 languages in your state. You may also consider signing up with a language assistance call center to help with the translation of documents as well as telephonic or in-person interpretation when needed. For example, some states’ Medicaid programs regard medical interpretation as a covered service and contract with a vendor to provide it. Your local hospital may also have interpreter resources. Finally, you should consider having commonly used documents translated for frequently used languages.

Enforcement of the new rule will fall to HHS’s Office of Civil Rights, which has indicated that it will use a flexible, context-specific analysis to determine any violations on a case-by-case basis. For additional information, check out the HHS summary and fact sheets and training materials .

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians




Friday, September 30, 2016

See if you’re due a penalty in the 2015 PQRS physician feedback report

Individual physicians and groups can now access their 2015 Physician Quality Reporting System (PQRS) Physician Feedback reports, which provide valuable information about your practice and whether you will face a Medicare penalty in 2017.

Physicians can access the reports through the CMS Enterprise Portal. Users must have an Enterprise Identity Management (EIDM) account with the appropriate role to access the reports. You can also access your Quality and Resource Use Reports (QRUR), which were also recently released, through the same portal.

The Physician Feedback reports will provide the determination on whether you met the PQRS criteria to avoid a 2 percent negative payment adjustment in 2017. Information is available for all measures reported by your National Provider Identifier (NPI) for each reporting method. You can review if your successfully reported all your measures and see a brief rationale for any payment adjustment, such as insufficient measures reported. It also includes reporting rate and performance rate percentages.

You can file an informal review request if you feel the negative payment adjustment was an error. The informal review period is open until Nov. 30. Reviews can be filed through the Quality Reporting Communication Support Page. For more information or additional questions, contact the QualityNet Help Desk at qnetsupport@hcqis.org or (866) 288-8912. A Feedback Report User Guide is available online.

The Centers for Medicare & Medicaid Services will mail out payment adjustment notification letters at a later date. Accessing the Physician Feedback reports now will allow you to review your performance and file an informal review before the deadline.

– Erin Solis, Regulatory Compliance Strategist at the American Academy of Family Physicians

Wednesday, September 28, 2016

QRUR reports for 2015 now available

The 2015 annual Quality and Resource Use Reports (QRUR) are now available to all group practices and solo practitioners. The report released by the Centers for Medicare & Medicaid Services (CMS) provides data on a practice’s performance on quality and cost metrics. The QRUR also provides information on how the practice fared under the 2017 Value-Based Payment Modifier (VBPM).

Authorized representatives can access the QRUR through the CMS Enterprise Portal with their Enterprise Identity Data Management (EIDM) credentials. You must have the correct role within the EIDM to access the report. CMS has provided guides on obtaining an EIDM account and how to obtain a QRUR.

Physicians will find in the reports performance information on the measures they submitted to the Physician Quality Reporting System (PQRS). CMS also calculates several claims-based quality and cost measures. Along with the QRUR, you can download an Excel file containing provider- and patient-level data. The information provided in the spreadsheets allows physicians to identify areas for improvement in cost and quality performance.

In 2017, all solo- and group-eligible professionals will be subject to the VBPM. Payment adjustments for the VBPM depend on practice size. It is important to review the information in the QRUR for accuracy. If you feel you have been assessed a payment penalty incorrectly, you can file an informal review through Nov. 30. You can submit a review through the CMS Enterprise Portal, or you can contact the Physician Value Help Desk at pvhelpdesk@cms.hhs.gov or 888-734-6433 (select option 3). The help desk is available by phone Monday-Friday 8 a.m.-8 p.m. EST.

Becoming familiar with the QRUR now is important as it will continue in some form under the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA's Merit-Based Incentive Payment System (MIPS) incorporates elements of PQRS and the VBPM. The initial performance period is slated to begin in 2017.

– Erin Solis, Regulatory Compliance Strategist for the American Academy of Family Physicians

Tuesday, September 27, 2016

Survey shows troublesome practice environment could affect patient access

Negative opinions about the state of medicine has large numbers of physicians planning to change their practices in ways that would decrease access to patients, according to a new study by The Physicians Foundation and Merritt Hawkins.

Almost half of the more than 17,000 physicians surveyed this spring said they planned over the next one to three years to cut back on hours worked, retire, take a non-clinical health care position, switch to a cash-only practice, or take other steps that would ultimate reduce access to patients.

"(The survey) reveals a physician workforce that continues to be dispirited about the current state of the medical profession and apprehensive about its future, due primarily to the large regulatory burden physicians face and the perceived erosion of their clinical autonomy," the researchers said in the report.

Overall, only 52 percent of physicians said they planned to remain working at the same level they are now. That represents a decline from 2014 when 56 percent of physicians surveyed said they didn't plan to change their practice.

The reasons for the negative changes are widespread. Almost 63 percent of respondents said they felt either "very" or "somewhat" pessimistic about the future of medicine, which was an increase from 51.1 percent in 2014. Eighty-one percent of physicians said they were overextended or at full capacity and unable to see more patients.

That said, many physicians aren't ready to abandon medicine entirely. Almost 72 percent of respondents said they would choose medicine as a career again, compared with 71 percent in 2014 and 67 percent in 2012. When asked if they would still recommend medicine as a career to their children or other young people, 51 percent said they would, up slightly from 50 percent in 2014.

Primary care physicians were a little more optimistic than their specialist peers, with 50.5 percent saying they are very or somewhat positive about the current state of medicine and 42.5 percent positive about the future of medicine. By comparison, 43.5 percent of specialists were positive about the present and 33.9 percent were positive about the future of medicine. Almost 73 percent of primary care physicians said they would choose medicine again as a career, compared with 71.4 percent of specialists, and 54 percent of primary care physicians said they would recommend medicine as a career to young people, compared with 50 percent of specialists.

The demographics of those responding to the survey showed the continuing trend of physicians leaving private practice for employed positions. Almost 33 percent characterized themselves as practice owners while about 58 percent said they worked for a hospital or large medical group. By comparison, 35 percent identified as practice owners in 2014 and 53 percent worked for large health groups and hospitals.

Looking at specific pieces of health care reform, only 43 percent said they were paid based on quality or value and 80 percent professed little knowledge of the Medicare Access and CHIP Reauthorization Act (MACRA). Only 11 percent of respondents said electronic health records have improve their interactions with patients, and only between 5 percent and 6 percent said the year-old ICD-10 coding has improved efficiency and revenues.

Wednesday, September 21, 2016

Codes for smoking and tobacco cessation counseling are changing

As part of its quarterly update to the Medicare physician fee schedule database, the Centers for Medicare & Medicaid Services (CMS) is changing the way you report smoking and tobacco cessation counseling to Medicare.

Effective for services on or after Oct. 1, CMS will no longer consider valid for Medicare purposes CPT codes G0436 (Smoking and tobacco cessation counseling visit for the asymptomatic patient; intermediate, greater than 3 minutes, up to 10 minutes) and G0437 (Smoking and tobacco cessation counseling visit for the asymptomatic patient; intensive, greater than 10 minutes).

CMS has advised its Medicare contractors to replace codes G0436 and G0437 with CPT codes 99406 (Smoking and tobacco use cessation counseling visit; intermediate, greater than 3 minutes up to 10 minutes) and 99407 (Smoking and tobacco use cessation counseling visit; intensive, greater than 10 minutes). Additional information on Medicare coverage of such counseling is discussed in Section 210.4.1 of the Medicare National Coverage Determination Manual.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, September 15, 2016

Grace period for ICD-10 coming to an end

We’ve almost completed a full year of ICD-10-CM use. Congratulations! The world didn’t stop turning on its axis; the sun didn’t explode. Now, we are ready for the next hurdle related to ICD-10: The end of the “grace period” extended by the Centers for Medicare & Medicaid Services (CMS).

What was the “grace period?" It was a 12-month period, beginning Oct. 1, 2015, during which CMS processed and paid any Medicare claim submitted with a valid ICD-10 code that was at least within the family (the first three digits) of the diagnosis in question. This period is ending Sept. 30 of this year, after which CMS and its contractors will require the diagnostic codes you submit to reflect documentation and be specific to the patient and condition.

What codes should you be wary of using? “Unspecified,” “NOS,” and “not otherwise specified” codes will gain particular scrutiny from CMS. These codes will often have the digit “9” as the fourth or sixth character.  

How do you determine if your coding is safe? This answer is a two-parter. First, you need to evaluate which ICD-10 codes you are submitting most often on your claims. When I was in clinic, my family doctors thought they used certain codes often. But after I ran reports to show which ones they actually used, they were often surprised. Running a report of your top 25, 50, or 100 ICD-10 codes will help you determine how often you are using unspecified codes and where you need to concentrate on being more specific. Second, make sure you monitor your Medicare administrative contractor’s Local Coverage Determination (LCD) policies and CMS’s National Coverage Determination (NCD) policies. These polices list the covered diagnoses for specific services you may be performing, ordering or referring. Familiarize yourself with these policies. It will save you and your staff time and heartaches – and maybe a few claim denials, too.

Where can I go to learn more? CMS has published frequently asked questions and other resources about ICD-10.

– Barbie Hays, CPC, CPMA, CPC-I, CEMC, Coding and Compliance Strategist for the American Academy of Family Physicians

Friday, September 9, 2016

CMS will let you pick your pace for MACRA compliance

Apparently acknowledging criticism that the timetable for physicians to participate in the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act (MACRA) next year may be too fast for some, the Centers for Medicare & Medicaid Services (CMS) is giving you some options.

In a blog post this week, Acting CMS Administrator Andy Slavitt laid out the four options, which let physicians and other providers pick the pace of their participation in the first performance period that begins Jan. 1. Choosing one of these options would ensure you do not receive a Medicare payment cut in 2019.

The first option is more of a test of the Quality Payment Program, allowing you to avoid the 2019 payment penalty if you submit at least some data after Jan. 1. The idea is that you will show your system is operating and prepared for broader participation in 2018 and 2019.

The second option is participating for part of 2017 as opposed to an entire calendar year. For example, Slavitt writes, you could submit data for a period starting later and Jan. 1 for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking. and still qualify for a small payment bonus.

If your practice was already expected to be prepared to participate fully in the Quality Payment Program on Jan. 1, you can take option three, which has you submitting a full calendar year of data for the program and qualifying for a modest positive payment adjustment.

The final option is to ignore submitting quality data and other information entirely and join an Advanced Alternative Payment Model in 2017, as provided in MACRA. Physicians who meet the required level of Medicare payments or patients through this alternative model would qualify for a 5 percent incentive payment in 2019.

CMS will provide more details about these options and the Quality Payment Program in general when it releases its final rule on MACRA implementation by Nov. 1.  

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

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