In June 2017, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule for Year 2 of the Quality Payment Program (QPP). As you are likely aware, the QPP, established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), is in its first year.
Since the program began, CMS has been soliciting feedback on how to streamline the QPP and reduce clinician burden, while preparing practices for participation. For the program’s second year, CMS wants to continue to receive stakeholder and clinician feedback while offering flexibility for participation.
The proposed rule is an attempt to make things easier for smaller, independent, and rural practices during the 2018 performance period. Here are 8 highlights:
- More physicians will be exempt from MIPS. For 2017, clinicians or groups were exempt from MIPS reporting if they billed $30,000 or less in Medicare Part B annually, or if they had 100 or fewer Medicare beneficiaries. Now CMS is suggesting raising this low-volume threshold in 2018 to 200 Medicare Part B beneficiaries and $90,000 Medicare Part B charges per year. This means that significantly more physicians won’t have to participate.
- Virtual groups are introduced. The proposed rule allows providers from practices of 10 or fewer, who are eligible for MIPS on their own, to participate as a virtual group and submit under group rules, instead of as an individual. This option was not available in 2017 and can help small practices combine administrative costs. To participate in a virtual group, a solo physician or group must combine with at least one other solo physician or group, no matter where located or what specialty, and register before the 2018 performance year (by December 1, 2017).
- Earn bonus points. Clinicians can earn bonus points if they care for complex patients (up to 3 points), are part of a practice with 15 or fewer clinicians (up to 5 points), or exclusively use the 2015 edition certified EHR technology (CERT). You may still use 2014 CERT for 2018, but will be rewarded for using 2015 CERT.
- Scoring. Scoring for MIPS in 2018 is weighted much like 2017: Quality is 60%, Cost is still 0%, advancing care information (ACI) is 25%, and improvement activities are 15%.
- Performance period. For 2017, to participate in MIPS you must submit data for a minimum of 90 days. In Year 2, the ACI and improvement categories still require 90 days of data, but you must submit a full year for the quality and cost performance categories.
- Performance threshold. For Year 1 the performance threshold, or the number that the clinician’s final score will be compared to, is 3 points. For Year 2 it’s 15 points. For Year 2 the exceptional performance threshold stays at 70 points. Total payment adjustment that can be distributed has also increased from 4% to 5% positive or negative for 2018.
- Submission mechanisms. For Year 1, all MIPS eligible clinicians are required to use only 1 submission mechanism per performance category. For Year 2, MIPS eligible clinicians can submit measures and activities via multiple submission mechanisms within a performance category.
- APM risk. Total potential risk must be equal to at least 8% of the average estimated Parts A and B revenue of the participating APM entities in 2017, and that standard is extended through performance year 2020.
To read the entire description of proposed changes, go to the CMS website. CMS continues to solicit additional comments on the QPP. You are encouraged to provide your input through August 21, 2017 by submitting your comments via email. When commenting, refer to file code CMS 5522-P.
In addition, CMS has provided several resources to assist clinicians with the QPP:
As you evaluate the right solution for your practice, know that Care360 EHR is fully certified for the QPP based on 2014 Edition Certification and the associated CMS regulatory requirements. Care360 is actively working to advance to the 2015 Edition Certification by January 2018, helping your practice earn bonus points. For more information on how the Care360 certified EHR can help, call us at 1.888.491.7900, or listen to our webinar featuring CMS officials who further explain this proposed rule.