Are physicians ready for / ? macra qpp Results from a KPMG-AMA Survey kpmg.com ama-assn.org Contents Summary Executive Summary 2 January 1, 2017 marked the beginning of the first performance Background and year of the Quality Payment Program (QPP) created by the Survey Objectives 5 Medicare Access and CHIP Reauthorization Act of 2015 What is MACRA? 5 (MACRA). Beginning in 2019, the QPP will adjust payment rates AMA and KPMG collaboration for physicians and other eligible health care professionals for to educate and support physicians 7 participation in 2017 under one of two payment tracks: (1) a Survey Objectives 7 payment system with incentives or penalties for reporting and Results 8 meeting certain quality measures, demonstrating use of a certified Knowledge of MACRA 9 electronic health record and other measures through the Merit- Participation 10 Based Incentive Payment System (MIPS); or, (2) a 5 percent lump Preparation 11 sum bonus payment if the physician has a threshold portion of Challenges 11 their revenue or patients in a qualifying Advanced Alternative Future Participation 13 Practice Size Effect 14 Payment Model (Advanced APM). In order to help ease the Specialty vs. Primary Care 15 transition to this new payment system, the Centers for Medicare Practice Setting Effect 16 and Medicaid Services (CMS) created a flexible “pick your pace” Level of Knowledge 17 reporting option for physicians. Additionally, CMS rules are likely PQRS and Meaningful Use to exclude nearly two-thirds of all clinicians from MIPS reporting Experience Effect 18 in 2017 (a large portion based on low volume thresholds or Verbatim findings 19 Advanced APM participation; Advanced APMs are also excluded Implications 20 from MIPS). Under the 2018 performance year proposed rule, Physicians Need More Help 21 even more physicians would be excluded in performance year Certain Challenges are Universal 21 2018 as a result of increasing the low volume threshold. Value-Based Care Reporting Experience Matters 22 More Alternative Payment Models are Needed 22 Physicians are Worried about Long-term Implications 22 Conclusion 23 There remains a significant QPP Appendices knowledge gap among physicians. Methodology and demographics 24 Survey Design and Fielding 24 Respondent Demographics 24 Analysis 25 Survey Questions 26 References 30 Contributors 31 © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of KPMG International. © 2017 American Medical Association, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the American Medical Association. All rights reserved. Despite efforts to ease the transition to MIPS and Some key findings from the survey of physicians involved in practice decision-making include: APMs, we are well into the first performance year and little is known about physicians’ preparation – A slight majority of respondents (51 percent) were somewhat knowledgeable about MACRA or the QPP, and operationalization of reporting requirements. whereas less than one in ten physicians (8 percent) felt deeply Given increasing participation requirements for knowledgeable about QPP and its requirements. Just over four physicians in future years, understanding where in ten physicians surveyed (41 percent) had heard of MACRA or QPP, but did not consider themselves knowledgeable. physicians are today with regard to readiness will help CMS, as well as medical societies and other – S even in ten respondents have begun preparing to meet supporting industry stakeholders, to better target the requirements of the QPP in 2017. Of those respondents, nearly nine in ten respondents feel somewhat prepared (65 educational outreach and help physicians prepare percent) or well prepared (23 percent) to meet requirements in for successful participation in the QPP. Feedback 2017. Of those planning to report through MIPS in 2018, only from physicians will also play a vital role in helping 65 percent feel prepared to meet requirements. to guide program implementation, including – Of those respondents expecting to participate in MIPS in 2017, potential revisions to the CMS proposed rule for the 90 percent feel MIPS requirements are slightly burdensome (37 percent) or very burdensome (53 percent). second performance year in 2018. – R espondents indicated that the time required to report is In order to better understand physician preparation and the most significant challenge today and expect that time positioning for QPP, KPMG and the American Medical for reporting will continue to be a challenge in subsequent Association surveyed 1,000 practicing physicians in the United years. Respondents also emphasized challenges with States who have some awareness of MACRA and are involved understanding requirements, understanding MIPS scoring, in practice decision-making related to QPP. Respondents and the cost of reporting. were from a variety of practice sizes, practice settings, specialties, and geographic regions. Although other surveys – P revious experience in other programs, including PQRS have explored the extent to which physicians are generally and Meaningful Use, appears to have contributed to familiar with MACRA, our survey focused on those physicians physician readiness for QPP; thus, getting experience now who have some knowledge of MACRA and are involved in in QPP at some level has the potential to set physicians up to practice decision-making in order to better understand gaps in potentially be more successful in the future than those with no understanding, early views and attitudes about the roll-out of the experience. However, it is particularly concerning that only 25 program, and physician plans for QPP participation. This is not percent of physicians with prior reporting program experience to say that awareness among physicians is not still a challenge. feel well prepared for the QPP. There remains a significant QPP knowledge gap among physicians. In this respect, the findings of this survey can assist – However, even those who feel prepared still don’t fully in indicating a glide path for more widespread QPP adoption in understand the financial ramifications of the program. In the future. short, they may be prepared to “check the box” of reporting requirements, but may lack the long-term strategic financial vision to succeed in 2018 and beyond. Only 8 percent of respondents feel they are “very prepared” for long-term 90% financial success, while 58 percent feel slightly prepared and 26 percent feel not at all prepared. of respondents feel MIPS requirements are slightly burdensome or very burdensome. © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Are physicians ready for macra/qpp 3 Summary (continued) The findings of the survey largely support a number of widely held assumptions about physician knowledge of and preparedness for QPP requirements: – S ome challenges are universal regardless of practice size, specialty, or previous value-based payment experience, particularly the time required and the complexity of reporting. – P hysicians, especially those in small practices, need more help in preparing. – P hysicians want more alternative payment model options available to them. – P hysicians with value-based payment reporting experience are more prepared and more confident about how they will perform under MIPS. – P hysicians remain deeply concerned about long-term financial ramifications of QPP. These findings have significant implications for physicians, as well as a number of other industry stakeholders as the QPP enters its second year. Policymakers must consider the existing challenges when crafting future policies and QPP requirements. CMS and professional medical societies, including the AMA, can use these findings to develop educational and training resources for physicians, including by targeting efforts to specific subsets of the population that appear to need the most help. This survey provides valuable insights into physician understanding of and preparedness for the QPP. Although some groups of physicians (larger practices, multi-specialty practices, and those with experience in value-based reporting programs) appear somewhat more prepared and optimistic about their performance in MIPS, a majority of physicians across practice sizes, practice settings, and specialties need more time to transition their practices to the new system. Additionally, physicians and the broader health care system need more alternative payment models to allow those who are ready to move more aggressively toward value-based care models that hold physicians accountable for the quality and cost of care they provide. CMS should consider the findings of this survey and others when crafting policies on participation requirements, implementation timelines, and other program specific regulations. © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of 4 Are physicians ready for macra/qpp KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Background and survey objectives What is MACRA? The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law on April 16, 2015, repealing the sustainable growth rate (SGR) formula used to determine physician payment updates in Medicare and replacing it with a stable 0.5 percent payment update until 2019. Compensation of physicians and other eligible professionals in payment year 2019 will be based upon their performance in 2017 in one of two available participation options under the QPP: 1. Merit Based Incentive Payment System (MIPS), a payment system with incentive payments or penalties for reporting or failing to report certain quality and efficiency measures; or, 2. An Advanced Alternative Payment Model (Advanced APM), a 5 percent bonus payment, and exclusion from MIPS, if the physician meets a threshold based on the portion of their revenue or patients covered under a qualifying Advanced APM. © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Are physicians ready for macra/qpp 5 Background and objectives (continued) CMS announced in May 2017 that more physicians would While CMS has assumed that these reporting options will help be excluded from MIPS reporting in 2017 (over 800,000 ease the transition to MIPS, little is known about physician clinicians) than originally projected (738,000 to 780,000), preparation and operationalization of program requirements for representing nearly two-thirds of all clinicians.i Under QPP. With more physicians and other clinicians expected to the 2018 performance year proposed rule, even more enter the QPP in future years, understanding where physicians physicians would be excluded in performance year 2018 are today with regard to readiness will help CMS, medical as a result of increasing the low volume threshold. But associations and other supporting industry stakeholders better significant challenges remain for those clinicians required target educational outreach that helps physicians and other to participate in MIPS in 2017 and beyond. clinicians prepare for success. Feedback from physicians will also play a vital role in helping to guide future rulemaking for the In order to address some of these challenges of complying and QPP, including for the second performance year in 2018. succeeding under MIPS, CMS established flexibility in reporting requirements for the first performance year (2017). In this transitional year, physicians can avoid any payment penalty in While CMS has assumed that 2019 by choosing one of the following reporting paths: these reporting options will help MIPS testing Report some data at any point in Calendar Year 2017 to ease the transition to MIPS, demonstrate capability by reporting on one quality measure, or one improvement activity, or the set of required ACI measures. little is known about physician There is no minimum reporting period. There is no negative adjustment in 2019. preparation and operationalization Partial MIPS reporting of program requirements for QPP. Submit partial MIPS data for at least 90 consecutive days in Calendar Year 2017. Report on 1 or more quality measure, or 1 or more improvement activities, or the set of required ACI measures. There is no negative adjustment in 2019 and the potential for some positive adjustment of less than 4 percent in 2019. Full MIPS reporting Meet all reporting requirements for at least 90 consecutive days in Calendar Year 2017. There is no negative adjustment in 2019 and there is the maximum opportunity for positive 2019 adjustments. Exceptional performances are eligible for additional positive adjustment of up to 10 percent. Only physicians who do NOT participate in any of the reporting paths in 2017 will be subject to penalties in 2019. CMS has proposed that physicians will again be able to avoid a negative payment adjustment in 2018 by doing less than full reporting in the second performance year—CMS estimated in its latest proposed rule that 94 percent of participants will receive a positive or neutral payment adjustment in 2018. © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of 6 Are physicians ready for macra/qpp KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Background and objectives (continued) AMA and KPMG collaboration to educate and support physicians Survey Objectives The Payment Model Evaluator (PME), designed and built by KPMG and the AMA in 2016, has been an effective web-based tool for exploring awareness of and preparation for MACRA.ii The PME, includes a brief self-assessment for physicians and A number of core questions drove their staff to determine the financial impact of the QPP on their practice alongside educational and actionable resources to development of the survey: prepare for the QPP. The tool was offered free of charge to all physicians and their practice administrators. 1 H ow knowledgeable are physicians In order to better understand physician preparation and about the QPP, in particular MIPS and its positioning for QPP, in the spring of 2017 KPMG and AMA program requirements? surveyed 1,000 practicing physicians in the United States who have been involved in practice decision-making related to QPP. 2 To what extent have physicians prepared Although previous surveys have explored the extent to which for the requirements of MIPS and physicians are generally familiar with MACRA, this survey operationalized changes within their only included physicians who have heard of MACRA and are practices to meet requirements in 2017? practice decision-makers in order to better understand gaps in understanding, early views and attitudes about the roll-out of the program, and physician plans for the program in the future. For 3 O f those physicians participating in additional details about the survey methods and demographics, MIPS in 2017, what level of reporting see Appendix A. are they planning to do under the “pick In addition to building on the work in the PME, the survey your pace” options? How do they plan augments the growing body of experiential knowledge gathered to participate in 2018 and future years? through feedback received during physician focus groups that informed creation of the PME, as well as feedback received 4 W hat are the most significant challenges by the AMA from the broader physician community, including for physicians participating in MIPS in through previous work with the RAND Corporation.iii The AMA the first year? will use the results of the survey to develop additional physician educational tools that meet the diverse needs of physicians in practices that vary by care setting, size, experience with value- 5 W hat areas do physicians need more based care, and level of knowledge. help in, and what role can CMS and medical associations play in filling knowledge gaps? 6 H ow many physicians feel prepared for long-term success under QPP? 7 W hat changes should CMS consider to improve the program in 2018 and beyond? © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Are physicians ready for macra/qpp 7 Results A slight majority of respondents (51 percent) were somewhat knowledgeable about MACRA or the QPP, whereas less than one in ten physicians (8 percent) felt deeply knowledgeable about QPP and its requirements. Just over four in ten physicians surveyed (41 percent) had heard of MACRA or QPP, but did not consider themselves knowledgeable. We surveyed 1,000 Seven in ten respondents have begun preparing to meet the requirements of the physicians who are QPP in 2017. Of those respondents, nearly nine in ten respondents feel somewhat involved in practice prepared (65 percent) or well prepared (23 percent) to meet requirements in 2017. Of those planning to report through MIPS in 2018, only 65 percent feel prepared to meet decision-making and requirements. This difference may be related to the yearly process of changes to the have at least some physician fee schedule. knowledge of MACRA Of those respondents expecting to participate in MIPS in 2017, 90 percent feel MIPS or QPP. Several requirements are slightly burdensome (37 percent) or very burdensome (53 percent). significant findings are further explored in Respondents indicated that the time required to report is the most significant challenge today and time for reporting will continue to be a challenge in subsequent subsequent sections. years. Respondents also emphasized challenges with understanding requirements, understanding MIPS scoring, and the cost of reporting. Previous experience in other programs, including PQRS and Meaningful Use, appears to have contributed to physician readiness for QPP; thus, getting experience now in QPP at some level has the potential to set physicians up to potentially be more successful in the future than those who do not have experience. However, it is particularly concerning that only 25 percent of physicians with prior reporting program experience feel well prepared for the QPP. However, even those who feel prepared don’t fully understand the financial ramifications of the program. In short, they may be prepared to “check the box” of reporting requirements, but they may lack the long-term strategic financial vision to succeed in 2018 and beyond. Only 8 percent of respondents feel they are “very prepared” for long-term financial success, while 58 percent feel slightly prepared and 26 percent feel not at all prepared. 51% Just over one- half of respondents were somewhat knowledgeable about MACRA or the QPP. © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of 8 Are physicians ready for macra/qpp KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Knowledge of macra A majority of the 1,000 physicians surveyed (those involved reform initiatives because they are more likely to be employed in practice decision-making) were somewhat knowledgeable and less involved in decision-making. The screening conducted (51 percent) or deeply knowledgeable (8 percent) of MACRA in this survey may have removed those in larger practices less or QPP; however 41 percent of those surveyed said they likely to know about MACRA, indicating that physicians in larger had heard of QPP, but would not consider themselves practices may have more value-based care experience and knowledgeable. knowledge. Physicians in larger practices (more than 10 physicians) were Respondents in multi-specialty group practices were more more likely to feel deeply knowledgeable of MACRA or QPP (11 likely to feel deeply knowledgeable (11 percent) than those in percent) than their counterparts in smaller practices (6 percent single-specialty group practices (8 percent), solo practices (7 for solo practitioners, 9 percent for those in practices of 2 to percent), or hospitals (8 percent) (see Figure 2). Specialists and 4, and 5 percent for those in practices of 5 to 10 physicians) primary care physicians were approximately equally likely to (see Figure 1). Previous surveys, including the AMA Physician feel deeply (9 percent and 7 percent, respectively) or somewhat Practice Benchmark Survey,iv have found that physicians in knowledgeable (50 percent and 51 percent, respectively) about larger practice sometimes have less knowledge of payment MACRA or QPP. Fig.1 Level of physician knowledge of macra/qpp by practice size 1 6% 48% 45% 2-4 9% 49% 42% 5-10 5% 49% 46% 11-24 11% 55% 34% 25-49 11% 61% 28% 50+ 11% 49% 40% 4 4 4 in-depth knowledge somewhat knowledgeable not knowledgeable Fig.2 Level of physician knowledge of MACRA/QPP by practice setting Single specialty 8% 50% 41% group practice Multi-specialty 11% 54% 35% group practice Solo practice 7% 49% 44% Hospital 8% 44% 49% 4 4 4 in-depth knowledge somewhat knowledgeable not knowledgeable © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the Are physicians ready for macra/qpp 9 Results (continued) Participation A majority of physicians surveyed (56 percent) expect to 2 percent expect to report as a MIPS APM in 2017; and 12 participate in MIPS in 2017, while just under 2 in 10 physicians percent do not know what level of reporting their practice will expect to meet the definition of Qualifying APM Participant do in 2017. The quality performance category is the one most (QP) and be exempt from MIPS reporting. Another 7 percent likely to be used (76 percent) by physicians planning to report expect to participate in an APM, but not meet the QP standard; only one measure in 2017. Nearly three-quarters (74 percent) of 8 percent do not expect to participate; and 12 percent do not MIPS participatin1g2 p%hysicians plan to report as a group, rather know whether and how they will participate in 2017. than as an individual; and three-fifths of all MIPS participants plan to use their electronic health record, (EHR), qualified Of the nearly 1 in 10 physicians not planning to participate in 8% registry, or qualified clinical data registry (QCDR) to report MIPS in 2017, nearly half (49 percent) had voluntarily chosen not performance in 2017, with 91 percent planning to report quality to participate; while the other half expected to be exempted as throug7h% their EHR or QCDR. a result of the low volume threshold for revenue (26 percent) 56% or patients (24 percent). [Note: the survey was fielded prior to Physicians expecting to be exempted from MIPS reporting as physicians and practices receiving formal notification from CMS a result of Advanced APM participation were most likely to be about whether they would be required to participate in MIPS in part of an organization in the Next Generation ACO model (54 2017]. percent); M18e%dicare Shared Savings Program (MSSP) Tracks 2 or 3 (50 percent); or Comprehensive Primary Care Plus (CPC+) Of those physicians planning to participate in MIPS, 3 in 10 plan (35 percent) [Note: some respondents indicated participation in to report the minimum possible (one measure) in 2017; one- multiple Advanced APMs, resulting in a total greater than 100 quarter plan to report partially (more than one measure) in 2017; percent]. 3 in 10 plan to opt for MIPS full reporting in 2017; 12% 12% 2% 30% 8% Fig.3 QPP Fig.4 MIPS 7% participation 56% 25% participation level in 2017° for physicians† 18% 30% 1 1 1 1 Participate in MIPS Advanced APM MIPS testing Full MIPS reporting 1 1 1 1 MIPS APM Not expecting to participate Partial MIPS reporting MIPS APM 1 1 Don’t know Don’t know ° Excludes 8% of resp1o2n%dents not planning to participate in QPP †Among those planning to participate in MIPS in 2017 2% 30% 25% 30% © 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, and logo are registered trademarks or trademarks of 10 Are physicians ready for macra/qpp KAPmMerGic Iannt eMrneadtiicoanla Al.s ©so 2c0ia1t7io Anm. Aellr ircigahnt Ms reedsiecravl eAds.sociation, an Illinois not-for-profit corporation. The AMA name and logo are registered trademarks of the
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