On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released a final rule for Year 3 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 currently in its second year.
CMS aims for the third year of the QPP to build upon the foundation that has been established in the first 2 years, which provides a trajectory for clinicians moving to a performance-based payment system.
But how will it affect your practice? Nine key highlights for Year 3 include:
- New clinician types. Expanding the definition of a Merit-based Incentive Payment System (MIPS)-eligible clinician to include new clinician types, including physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutrition professionals.
- Who participates. CMS has elected to finalize the MIPS low-volume determination at $90,000 of Medicare Part B charges or 200 Part B-enrolled beneficiaries, or 200 or fewer covered professional services to Part B-enrolled individuals. Therefore, any clinician who exceeds all three criteria will be required to participate in MIPS, while any clinician who falls below the threshold for any of the three criteria will be excluded from MIPS participation. If an eligible clinician does not meet eligibility requirements, they will not be penalized under the MIPS program for not submitting data. If an eligible clinician chooses to opt-in voluntarily, but does not meet the 3 requirements, they will not earn an incentive payment, nor will they be penalized. CMS also added a third element (Number of Covered Professional Services) to the low-volume threshold determination and provided an opt-in policy that offers eligible clinicians who meet or exceed one or two, but not all, elements of the low-volume threshold the ability to participate in MIPS.
- Performance threshold. CMS finalized increasing the MIPS performance threshold for neutral adjustments from 15 points in 2018 to 30 points for 2019. Additionally, the exceptional performance bonus threshold has been raised from 70 to 75 points for 2019. By statute, the minimum and maximum MIPS payment adjustments increase from +/- 5% to +/- 7%, however the exact application of these adjustments will depend on a scaling factor to preserve budget neutrality.
- Name change. CMS finalized the title change of the MIPS performance category “Advancing Care Information” to “Promoting Interoperability,” and finalized proposals for the minimum 90-day reporting period and realignment of the various special status determination periods. Also, moved clinicians to a smaller set of objectives and measures with scoring based on performance for the Promoting Interoperability performance category.
- Category weights. Cost category will be 15% in 2019. Quality category will be weighted at 45%, while promoting interoperability and improvement activities will remain at 25% and 15%, respectively.
- Quality category. Specific to the quality performance category, CMS has elected to maintain the data completeness requirement for quality measures at 60% for 2019. Bonus points will continue to be available for clinicians who submit additional high priority or outcome measures beyond the one required and for clinicians who submit quality measures using end-to-end electronic reporting.
- EHR certification. CMS finalized the requirement of 2015 Edition certified EHR technology for those actively participating in the Promoting Interoperability performance category beginning in the 2019 performance period.
- Inclusion of virtual care. For the first time this rule will also provide access to “virtual” care. Medicare will pay providers for new communication technology-based services, such as brief check-ins between patients and practitioners, and pay separately for evaluation of remote pre-recorded images and/or video. CMS is also expanding the list of Medicare-covered telehealth services. This will give seniors more choice and improved access to care.
- Facility-based scoring. Applying facility-based scoring automatically for eligible facility-based clinicians without data submission requirements for individual clinicians and using group data submission in the MIPS Promoting Interoperability or Improvement Activities categories to identify groups for facility-based scoring determinations. A facility-based group is one in which 75 percent or more of the MIPS eligible clinician NPIs billing under the group’s TIN are eligible for facility-based measurement as individuals. There are no submission requirements for individual clinicians in facility-based measurement, but a group must submit data in the Improvement Activities or Promoting Interoperability performance categories in order to be measured as a group under facility-based measurement.
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, and our 2015 Edition Certification will be complete by December 31, 2018.
If your practice is required to submit and wants to avoid the penalty, they will need to report for MIPS. We can help. For more information, call Quest Diagnostics at 1.888.491.7900.