On June 20, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a Notice of Proposed Rulemaking with updates to the implementation of the Medicare and CHIP Reauthorization Act of 2015 (MACRA) and the Quality Payment Program (QPP). MACRA requirements on Medicare Part B providers are already in effect this year (2017), with payment adjustments under the new system due to start in 2019.

While the proposed rule moderately increases the minimum scoring threshold for providers to avoid a negative payment adjustment, it continues CMS’s “go slow” trajectory for the QPP with slight course corrections that: (1) make it easier for smaller providers to receive an exemption from the program, (2) reduce the performance and reporting requirements within the Merit-Based Incentive Payment System (MIPS), and (3) seek additional opportunities for providers to be considered participants in Advanced Alternative Payment Models (A-APMs). Key changes proposed for 2018 include:

  • Raising the MIPS threshold score (i.e., the score below which a participant would receive a negative payment adjustment) to 15 out of a possible 100, up from a score of three for Program Year 2017;
  • Elevating the minimum Medicare volume threshold for participation in MIPS, relative to Program Year 2017 (to $90,000 in allowed charges, or 200 Part B beneficiaries), which would exempt more than 60% of otherwise-eligible clinicians from the program;
  • Implementing “virtual groups” to allow clinicians and practices to band together for MIPS reporting and receive a single score;
  • Introducing an alternative MIPS scoring methodology for facility-based clinicians that aligns with the Hospital Value-Based Purchasing program in Medicare Part A;
  • Delaying incorporation of the cost-scoring component of MIPS until Program Year 2019;
  • Delaying the requirement for use of 2015 Certified EHR Technology under MIPS; and
  • Proposing additional ways in which clinicians may qualify to receive the 5% bonus in the A-APMs track, which involve participation in a combination of Medicare Advanced APMs and Advanced APMs outside the Medicare fee for service program (e.g., within Medicare Advantage, Medicaid and/or commercial contracts), referred to as the “All-Payer Combination Option.”