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Quality Payment Program: A new compliance frontier

Raul G. Ordonez (raul.ordonez@jhsmiami.org) is Director, Compliance in the Office of Compliance and Ethics at Jackson Health System, Miami, FL.

With the passage of the Medicare Access to Care and CHIP Reauthorization Act of 2015 (MACRA), Congress set out to transform the US clinician compensation structure from a system that rewards providers for the volume of patients treated to a system that is “outcome-focused, patient-centered, and resource-effective.”[1]

For many, the passage of MACRA signaled the arrival of the forthcoming shift in US healthcare to an emphasis on value. Beginning in 2017, qualifying providers were required to participate in either an Advanced Alternative Payment Model (APM) or in the Merit-Based Incentive Payment System (MIPS). Both programs involve the submission of data relating to value-based treatment activities in return for incentive payments. Starting in 2019, CMS will begin to make the incentive payments resulting from providers’ year 2017 submissions. Now that providers will begin receiving payment from CMS related to these programs, it is as good a time as ever to consider the compliance risk associated. This article will provide an overview of the Quality Payment Program, explore the prospect of regulatory enforcement relating to the program, and consider best practices to help ensure compliance.

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