On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) released a final 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.
This final rule includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2018. The calendar year 2018 PFS final rule is one of several final rules that reflect a broader Administration-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment, and innovation, according to CMS.
The proposed rule is an attempt to make things easier for smaller, independent, and rural practices during the 2018 performance period. Here are 9 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. In 2018, the low-volume threshold will be practices with 200 Medicare Part B beneficiaries, and the reimbursement threshold will be $90,000 in 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 solo practitioners and small practices, who are eligible for MIPS on their own, to participate as a virtual group and submit under group rules, instead of as an individual. A virtual group is a combination of 2 or more Taxpayer Identification Numbers made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together virtually. This option, which was not available in 2017, can help small practices combine administrative costs.
- Earn bonus points. Clinicians can earn 5 bonus points on their MIPS final score if they care for complex patients, 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 receive a 10% bonus for using 2015 CERT.
- Scoring. Scoring for MIPS in 2018 (the 2020 payment year) is weighted accordingly: Quality is 50% (it will be 30% in 2019 and beyond), Cost is 10% (and will be 30% in 2019 and beyond), advancing care information (ACI) is still 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.
- Submission mechanisms. For Year 1, all MIPS-eligible clinicians are required to use only 1 submission mechanism per performance category. For Year 2, there is no change. (For Year 3, you will be able to use multiple submission mechanisms).
- 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.
- Natural disaster consideration. The final rule automatically weights the Quality, Advancing Care information, and Improvement Activities performance categories at 0% of the final score in the 2017 transition year for clinicians impacted by hurricanes Irma, Harvey, and Maria, and other natural disasters during the 2017 MIPS performance period.
For an executive summary of the final rule, go to the CMS website.
As you evaluate the right solution for your practice, know that Quanum™ EHR is fully certified for the QPP based on 2014 Edition Certification and the associated CMS regulatory requirements. Quanum’s 2015 Edition Certification is on track for 2015 certification in 2018, and may help your practice earn bonus points. For more information on how the Quanum certified EHR can help, call us at 1.888.491.7900, or sign up for our December webinar featuring CMS officials who will further explain this Year 2 final rule.