By LeeAnn Hastings, Caravan Health, Director of Policy and Compliance
The Physician Fee Schedule (PFS) final rule was released by CMS in early November. The rule broadly establishes payment rates for physicians and makes other changes to the Medicare Part B program for calendar year 2017 (CY2017). Among the changes finalized for 2017 include important modifications to the Medicare Shared Savings Program for Accountable Care Organizations (ACOs) and their participant providers.
In the final rule, CMS created some important flexibility for providers that participate in an ACO and looking ahead, an opportunity for providers to increase the certainty of their patient population.
Typically, an ACO is responsible for reporting required quality data on behalf of its providers. Providers that do not report this data are currently penalized, or in the case of ACO participants, if the ACO does not report on their behalf. With the new rule, CMS will now allow providers to independently report their quality data, which in the event their ACO fails in its obligation, will prevent the provider from facing a penalty. The rule allows physicians to back-report for both the 2015 and 2016 performance years; and will carry forward the policy as we shift to payment under the Quality Payment Program (QPP) in the 2017 performance year.
CMS also finalized its proposal to explore a voluntary attestation process for 2018. Under this system, patients would be able to declare their “home” doctor, and the ACO would know in advance that such patients were assigned to the ACO. More details on this process will be released through sub-regulatory guidance and outreach.
Finally, CMS used the final rule to make adjustments to the quality measure set for 2017. More information on technical changes to quality measures and quality validation is contained in the PFS Shared Savings Program brief HERE.
In future blog posts we will discuss important coding changes in the final rule as well as the expanded Diabetes Prevention Program.