On December 21, 2016, the HHS OIG posted a report summarizing its early review of CMS’s management of the implementation of the Quality Payment Program (QPP) and related findings (“Report”).  The Report concludes that, while CMS has made significant progress toward implementing the QPP, two vulnerabilities remain: (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.

The QPP, which is a set of clinician payment reforms with an increased focus on the quality and value of care, is part of the implementation of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) by CMS.  The QPP is a significant deviation from historical clinician payment calculations, which means CMS must develop a new system for measuring, reporting, and scoring the value and quality of care.  The first payment adjustments based on QPP performance measures go into effect on January 1, 2019.  To meet this statutory deadline, CMS issued final regulations implementing the QPP on October 14, 2016, and established the first performance year for clinicians as January 1, 2017. 

Due to the amount of development and implementation that is required of CMS within a short time frame, the OIG conducted an early review of CMS’s management of QPP implementation to evaluate CMS’s progress and identify key challenges and potential vulnerabilities.

According to the OIG, CMS is focused on clinicians’ acceptance of the QPP, and readiness to participate in it, based on CMS’s belief that it is critical to ensuring the program’s success.  This focus on clinicians informed CMS’s decision making regarding its other management priorities, including: 

• adopting integrated internal business practices to accommodate a flexible, user-centric approach;
• developing IT systems that support and streamline clinician participation;
• developing flexible and transparent MIPS policies; and
• facilitating participation in Advanced APMs.

The Report states CMS has made “significant progress” towards implementing the QPP, including:

• finalizing key policies to implement the QPP, including issuing final regulations and identifying Medicare models that qualify as Advanced APMs for the first performance period;
• initiating engagement and outreach activities to clinicians;
• launching a public-facing informational website; and
• awarding various contracts for technical assistance and training.

However, according to the Report, CMS still needs to expand its technical assistance efforts, issue promised sub-regulatory guidance, award and oversee key contracts, and complete development of the back end IT systems supporting QPP operations.  In addition, the Report identifies two critical vulnerabilities that should be addressed in 2017, due to their potential impact on the program’s success: 

• providing sufficient guidance and technical assistance to ensure that clinicians are ready to participate in the QPP, and
• developing IT systems to support data reporting, scoring, and payment adjustment.