{"id":101,"date":"2018-02-13T05:09:00","date_gmt":"2018-02-13T00:09:00","guid":{"rendered":"http:\/\/www.policymed.com\/oig-releases-review-of-qpp\/"},"modified":"2018-05-04T00:58:15","modified_gmt":"2018-05-03T19:58:15","slug":"oig-releases-review-of-qpp","status":"publish","type":"post","link":"https:\/\/www.policymed.com\/2018\/02\/oig-releases-review-of-qpp.html","title":{"rendered":"OIG Releases Review of QPP"},"content":{"rendered":"<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The Office of the Inspector General (OIG) <a href=\"https:\/\/oig.hhs.gov\/oei\/reports\/oei-12-17-00350.pdf\">released a review<\/a> of the Quality Payment Program (QPP), concluding CMS has made progress towards implementing the QPP, but challenges remain. CMS appears on track to deploy the IT systems needed for data submission but the OIG has identified two vulnerabilities that are critical for CMS to address in 2018 because of their potential impact on the program&#8217;s success.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\"><strong>OIG Study<\/strong><\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">According to the OIG, it interviewed CMS staff and reviewed internal CMS documents as well as publicly available information. The OIG conducted qualitative analysis to identify key milestones (both those achieved and those yet to come), priorities, and challenges related to QPP implementation.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">In 2016, OIG conducted an early implementation review of CMS\u2019s management of the QPP. It found that CMS had made significant progress towards implementing the QPP, including fostering clinician acceptance, adopting integrated business practices, building IT systems, and developing key program policies.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">However, the review also identified two potential vulnerabilities that were critical for CMS to address in 2017 because of their potential impact on the program\u2019s success: (1) Completing information technology systems to support critical QPP functions. In the past, CMS has experienced delays and complications related to major information technology (IT) initiatives. If CMS does not complete the complex IT systems underlying the QPP on schedule, implementation of quality-based payment adjustments may be delayed. (2) Ensuring clinician readiness to participate in the QPP. If clinicians lack sufficient information and assistance, they may struggle to meet QPP reporting requirements or choose not to participate at all.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The OIG\u2019s objectives in this follow-up review were to assess CMS\u2019s progress in mitigating these potential vulnerabilities and to identify emerging challenges. If CMS fails to sufficiently address these issues, the QPP may be unable to achieve its goal of promoting high-value care and patient outcomes while minimizing burden on clinicians.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\"><strong>Large IT System Necessary to Support QPP<\/strong><\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">As described by the OIG, building the IT systems to support the QPP is a significant undertaking for CMS, requiring both public-facing products (e.g., an interface for data submission) and back-end systems (e.g., a module to calculate MIPS final scores). These complex systems must be completed on schedule so that key elements of the program, such as data submission, can occur according to the timeframe specified in statute and regulation. The IT systems for the QPP encompass the following six products:<\/span><\/p>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The platform is the infrastructure that underlies and supports all of the other QPP products. It ensures that various development efforts are coordinated and employ common methods.<\/span><\/li>\n<\/ul>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The website is the central site where all clinicians, their partners, and developers interested in interacting with the QPP come to perform tasks. Ultimately, it will include both public webpages with general information and other pages where individual users can access secure, authenticated accounts providing QPP performance information.<\/span><\/li>\n<\/ul>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The eligibility product uses CMS data sources to determine clinicians\u2019 eligibility for the QPP (i.e., whether they are required to participate to avoid a negative payment adjustment), including whether they are qualified to participate under the MIPS track or the Advanced APM track.<\/span><\/li>\n<\/ul>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The data submission product enables clinicians, as well as other staff or vendors authorized to provide data on their behalf (e.g., office administrators, registries), to submit MIPS data to CMS. CMS will support a variety of submission mechanisms.<\/span><\/li>\n<\/ul>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The scoring product will enable CMS to calculate each clinician\u2019s final MIPS score based on the data submitted. These scores will also be used to determine the payment adjustment that each MIPS clinician will receive in 2019.<\/span><\/li>\n<\/ul>\n<ul>\n<li><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">The feedback product will produce individualized reports providing clinicians with information about their performance, including their respective final MIPS scores and payment adjustments.<\/span><\/li>\n<\/ul>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">In its assessment, the OIG states, \u201cIT development appears on track to deploy all products necessary for data submission to begin on January 1, 2018.\u201d This is good news for CMS, as the first vulnerability described by the OIG is related to the agency\u2019s IT systems. Specifically: \u201cIf clinicians do not receive sufficient information and assistance, they may struggle to succeed under the QPP or choose not to participate. This is of particular concern for small practices and clinicians in rural or medically underserved areas, who may lack the resources to fully engage in the QPP without customized technical assistance to meet practice-specific needs,\u201d says the OIG.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\"><strong>Clinician Readiness for QPP<\/strong><\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">As described by the OIG, CMS officials have consistently stated that clinicians\u2019 acceptance of and readiness to participate is crucial to the program\u2019s success. For 2017\u2014the program\u2019s first performance period\u2014CMS set a goal of 90 percent participation in QPP. To reach this goal, CMS has used multiple channels to educate clinicians, provide technical assistance, and collect feedback. For example, CMS held numerous webinars and other events; issued subregulatory guidance; and established a Service Center to respond to questions and resolve problems. CMS also awarded a variety of contracts to provide technical assistance specific to clinicians\u2019 practice types and needs.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">Through these efforts, CMS has raised awareness of the QPP, and a majority of eligible clinicians have reported to CMS that they intend to participate. CMS staff said that because the QPP was an entirely new initiative, it was necessary for early outreach efforts to focus on general education and awareness. However, CMS staff report that as QPP implementation continues, a greater focus on specialized, practice-specific technical assistance will be needed to help clinicians fully participate in the new program.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">This results in the second vulnerability outlined by the OIG. If clinicians do not receive sufficient technical assistance, they may struggle to succeed under the QPP or choose not to participate. According to clinician feedback collected by CMS demonstrates widespread basic awareness of the QPP, but also indicates uncertainty regarding details of participation such as who must report and how to submit data.<\/span><\/p>\n<p><span style=\"font-family: arial, helvetica, sans-serif; font-size: 11pt;\">Further, to date, CMS contractors have focused largely on general education initiatives, with fewer resources devoted to more customized, practice-specific technical assistance. CMS needs to continue to assess progress and increase the proportion of contractors\u2019 efforts devoted to specialized technical assistance to support high levels of clinician participation. Small practices and clinicians in rural or medically underserved areas, who may have fewer administrative resources and less experience with prior CMS quality programs, should be prioritized for assistance, according to the OIG.<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"<p>The Office of the Inspector General (OIG) released a review of the Quality Payment Program (QPP), concluding CMS has made progress towards implementing the QPP, but challenges remain. CMS appears on track to deploy the IT systems needed for data submission but the OIG has identified two vulnerabilities that are critical for CMS to address [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":3632,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[31,28],"tags":[1101],"class_list":["post-101","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-hhs-oig","category-macra","tag-new"],"_links":{"self":[{"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/posts\/101","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/comments?post=101"}],"version-history":[{"count":2,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/posts\/101\/revisions"}],"predecessor-version":[{"id":3633,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/posts\/101\/revisions\/3633"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/media\/3632"}],"wp:attachment":[{"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/media?parent=101"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/categories?post=101"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.policymed.com\/wp-json\/wp\/v2\/tags?post=101"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}