CMS has issued a final rule with comment period making changes to the Quality Payment Program (QPP) for 2018, the second performance year for the reformed physician payment framework mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS is continuing its “slow ramp-up” of the QPP by building on the transition policies established for 2017. In the 2018 rule, CMS intends to encourage successful QPP participation under either the Merit-based Incentive Payment System (MIPS) or the Advanced Alternative Payment Model (APM) track while reducing burdens on clinicians.
With regard to MIPS participation, the final rule:
- Reweighted the performance category scoring for 2018 as follows: Quality 50%, Cost 10%, Improvement Activities 15%, and Advancing Care Information 25%.
- Increased the performance threshold to 15 points in year two (up from 3 points in 2017).
- Established a Virtual Groups participation option under which solo practitioners and groups of 10 or fewer eligible clinicians that exceed the low-volume threshold may come together “virtually” to participate in MIPS for a one-year performance period.
- Increased the low-volume threshold to less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries (up from $30,000 charges/200 beneficiaries) in order to exclude more practices.
- Provided bonus points for: the treatment of complex patients; use of only the 2015 Edition Certified Electronic Health Record Technology; and clinicians and small practices that submit data on at least one performance category in an applicable performance period.
- Implemented an optional facility-based scoring mechanism for facility-based clinicians, beginning with the 2019 performance year.
- Created hardship exemptions in the Advancing Care Information performance category.
- Added a new improvement activity for clinicians who attest to consulting specified applicable appropriate use criteria (AUC) through a qualified clinical decision support mechanism for outpatient advanced diagnostic imaging services ordered (applicable to clinicians who are early adopters of the Medicare AUC program in the 2018 performance year for clinicians that begin the Medicare AUC program in future years as specified in separate regulations).
- Promulgated an interim final rule with comment period to address extreme and uncontrollable circumstances MIPS eligible clinicians may face as a result of widespread catastrophic events affecting a region or locale in CY 2017, such as Hurricanes Irma, Harvey and Maria.
CMS also adopted a number of policies affecting APM participants. For instance, the final rule:
- Extended the current revenue-based nominal amount standard through performance year 2020 (which allows an APM to meet the Advanced APM financial risk criterion if participants are required to bear total risk of at least 8% of their Medicare Parts A and B revenue).
- Revised the timeframe for making qualifying APM participant determinations.
- Provided additional details on implementation of the All-Payer Combination Option, which will be available beginning in performance year 2019.
- Provided a more gradual increase in the financial risk requirement for Medical Home Models.
CMS estimates that approximately 185,000 to 250,000 eligible clinicians may become Qualifying APM Participants for payment year 2020 based on Advanced APM participation in performance year 2018.
CMS will accept comments on the rule until January 1, 2018. CMS has posted additional resources regarding the QPP program here.