OIG Issues Review of CMS’s Quality Payment Program


The Department of Health & Human Services, Office of Inspector General (OIG) issued an Early Implementation Review of CMS’s Quality Payment Program (QPP), a key component of the MACRA law that reforms clinician compensation from a volume-based model to a quality- and value-based model, just ahead of the first performance year for the new payment systems. The OIG found that while Centers for Medicare & Medicaid Services (CMS) has made significant progress in implementing the reforms, some weaknesses exist in the implementation process.

The report does not reflect CMS’s management of the QPP or its merits or likelihood of success. Rather, it focuses on five key management priorities regarding the planning and early implementation of the QPP: (i) adopting integrated business practices to accommodate a user-centric approach;(ii) developing IT systems that support clinician participation; (iii) developing flexible and transparent Merit-Based Incentives (MIPS); (iv) facilitating participation in alternative payment models (APMs); and (v) fostering clinician acceptance and participation.
Although OIG applauded that CMS in certain areas, OIG highlighted several areas where CMS needs to focus efforts to ensure a continued successful implementation of the program. Specifically, OIG calls for CMS to focus on small, solo and rural providers who are historically less likely to participate, as well as the need to build and test the complex IT systems necessary to support full implementation of the program. CMS has replied that it will focus its efforts on the IT systems necessary for the rollout and is working with clinicians to ensure the program is accessible and user friendly. 2017 will be the first performance year for the QPP, with any payment adjustments taking place on January 1, 2019.

Related Practices:   Healthcare Law

Related Attorney:   John D. Fanburg, Carol Grelecki