On June 20, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for the CY 2018 Updates to the Quality Payment Program. As a refresher, the Quality Payment Program has two pathways for clinicians – (1) Merit-based Incentive Payment System (MIPS) or (2) Advanced Alternative Payment Models (Advanced APMs) – and began in CY 2017. After receiving feedback from the healthcare community, CMS made 2017 a transition year allowing clinicians to “pick their pace” and issued preliminary policies.
As we approach 2018, CMS is preparing for its first non-transition year and amending some existing requirements and adding policies for clinicians participating in the Quality Payment Program. The objective of the proposed rule is to continue to push clinicians towards value-based care while providing flexibility and limiting administrative burdens. .
MIPS TRACK HIGHLIGHTS
Exemption – CMS proposed to lower the low volume threshold so smaller practices and eligible clinicians in rural and healthcare provider shortage areas are exempt – bill $90,000 or less in Medicare Part B charges annually or have 200 or fewer Part B beneficiaries.
2018 Scoring –
- Quality: 60%
- Cost: 0%
- Advancing Care Information: 25%
- Improvement Activities: 15%
Bonus Points – Bonus points proposed for the following:
- Care for complex patients (up to 3 points)
- Practice with 15 or fewer clinicians (up to 5 points)
- Exclusive use of the 2015 Edition Certified EHR Technology (allow use of 2014 CEHRT but using bonus points to encourage adoption of 2015 version)
Virtual Groups – CMS proposed the option for clinicians to form virtual groups to virtually combine for MIPS participation. Solo physicians or groups of 10 or fewer clinicians can combine and would be required to register before the 2018 performance year.
In addition to the highlights above, CMS also proposed: providing more flexibility/incentives for clinicians in small practices; incorporating an option to use facility-based scoring for facility-based clinicians; and, integrating policy from the Appropriate Use Criteria and 21st Century Cures Act. In addition to the MIPS changes and additions, CMS proposed to keep many of the policies for APMs that were finalized in the 2017 transition year.
To compare 2017 to the proposed changes and additions in the recent proposed rule, reference the Fact Sheet comparison chart.