What OIG Found. During 2017, CMS made significant efforts to address the two vulnerabilities that OIG identified in its 2016 management review--developing IT systems and preparing clinicians to participate in the QPP. With regard to IT, CMS appears on track to deploy the systems needed for data submission by January 1, 2018. It has added new content and functionality to the public website; deployed an IT product to make eligibility determinations; and tested, but not yet fully deployed, applications to support data submission and real-time scoring. With regard to clinician readiness, CMS has conducted outreach, communicated eligibility information, issued subregulatory guidance, and established a Service Center to respond to questions. CMS also awarded a variety of technical assistance contracts; however, contractors' efforts to date have focused primarily on general education for a broad audience rather than specialized technical assistance to address practice-specific needs. Clinician feedback collected by CMS demonstrates widespread awareness of the QPP, but also uncertainty about eligibility, data submission, and other key elements of the program. With regard to emerging challenges, we found that CMS has not yet developed a comprehensive program integrity plan for the QPP. Appropriate oversight--particularly to ensure the accuracy of clinician-submitted data--is critical to prevent improper QPP payment adjustments. Although CMS included oversight provisions in the QPP final rule for 2017 and has initiated oversight planning, it still needs to clearly designate leadership responsibility for QPP program integrity and develop a plan to prevent and address fraud and improper payments.
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