Early Implementation Review: CMS's Management of the Quality Payment Program

WHY WE DID THIS STUDY

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) enacted clinician payment reforms designed to put increased focus on the quality and value of care. These reforms, known as the Quality Payment Program (QPP), are a significant shift in how Medicare calculates compensation for clinicians and require CMS to develop a complex system for measuring, reporting, and scoring the value and quality of care. CMS issued final regulations on October 14, 2016, and the first performance year will begin January 1, 2017, with the first payment adjustments taking effect on January 1, 2019. Clinicians may participate in one of two QPP tracks: the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs).

Given the importance and complexity of these payment reforms and the tight timeline to launch the program, OIG conducted an early implementation review of CMS's management of the QPP. We did not assess the extent to which the QPP will be successful in meeting program requirements and goals.

HOW WE DID THIS STUDY

We interviewed CMS staff and reviewed internal CMS documents as well as publicly available information. We conducted qualitative analysis to identify key milestones (both those achieved and those yet to come), priorities, and challenges related to QPP implementation.

WHAT WE FOUND

From our analysis, we identified CMS's five key management priorities regarding the agency's planning and early implementation of the QPP. Early on, CMS staff decided 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 on clinicians informed CMS's 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.

As of December 2016, CMS had finalized key policies to implement the QPP, including issuing final regulations and identifying Medicare models that qualify as Advanced APMs for the first performance period. CMS had also initiated engagement and outreach activities to clinicians, launched a public-facing informational website, and awarded various contracts for technical assistance and training. CMS must still expand its technical assistance efforts, issue promised subregulatory guidance, award and oversee key contracts, and complete development of backend IT systems necessary to support critical QPP operations.

WHAT WE CONCLUDE

CMS has made significant progress towards implementing the QPP. Although many milestones remain before the QPP payment adjustments in 2019, OIG identified two vulnerabilities that are critical for CMS to address in 2017, because of their potential impact on the program's success: (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.