On November 2, the Centers for Medicare & Medicaid Services (CMS) released its final rule governing its Medicare Quality Payment Program in 2018. According to a recent article in Medical Economics, below are the top things physicians need to know about the 2018 rule for the Quality Payment Program:
As a way to extend flexibility CMS notes, physicians or groups eligible for participation in the Merit-based Incentive Payment System (MIPS) with $90,000 or less in Medicare Part B allowed charges or 200 or fewer Part B beneficiaries will not be required to participate in quality metric reporting. This is the same as the proposed rule released in June.
MIPS category percentages shift
For 2018, the cost category will represent 10% of eligible physicians’ MIPS score. This is a 10% increase over the proposed rule. The cost will be calculated through Medicare Spending per Beneficiary (MSPB) and total per capita cost measures for 2018 – carryovers from the Value Modifier program.
The quality performance category shifts from 60% of a physician’s score this year to 50% in 2018. In 2019, quality drops to 30% of a clinician’s overall score. The advancing care information category (25%) and clinical improvement activities (15%) categories retain their percentages next year as well as the 90-day reporting period.
New clinical improvement activities
In addition to changing 27 previously adopted clinical improvement activities, CMS is finalizing 21 new activities for 2018. These include achieving health equity via participation in clinical trials, research alliances or community-based research, providing education opportunities for new clinicians and sharing EHR systems between primary care and behavioral health practices.
MIPS performance threshold raised
The threshold for scoring system performance increased from 12 points to 15 points for 2018. Eligible clinicians must report data to qualify for a minimum of those 15 points from MIPS categories in order to receive a neutral payment adjustment (neither a penalty nor a bonus). Payments will be adjusted up or down 4% for the current year.
No rush to switch EHRs
The original requirements of using a 2015 Certified Electronic Health Record (EHR) was seen as a burden for practices, especially smaller ones. CMS will allow the use of a 2014 Edition EHR and will provide a bonus to practices with a 2015 Edition system.
Recognition of complex patients
With the ongoing discussions regarding complex patients, CMS will award five bonus points in the MIPS program for treatment of complex patients. Complex patients will be determined by a combination of Hierarchical Condition Categories and the number of dually eligible patients a practice treats.
Relief for practices and patients affected by hurricanes
CMS will is offering relive to physicians and to citizens whose enrollment in Medicare Part A or Part B for the coming year is affected by recovering from recent natural disasters. This affects physicians in the areas impacted by hurricanes Irma, Harvey, Maria and other recent natural disasters for both the current reporting year as well as 2018.
MIPS-eligible clinicians who are able to report data for 2017 will be rewarded for their performance, but those who cannot report due to the natural disaster will not face a penalty in 2019.
Bonus for small practices
Practices defined as having 15 or fewer eligible clinicians are considered small practices. They will be awarded five bonus points on their MIPS final scores as long as the eligible physician (or group) submits date for at least one performance category
CMS will continue to award small practices three points for measures in the quality performance category that don’t meet data completeness requirements for an entire patient panel.
Creation of virtual groups
Initially unveiled in the 2018 proposed rule, CMS will permit creation of “virtual groups” for solo practitioners and groups of 10 or fewer eligible clinicians. These professionals can partner with at least one other group to report MIPS quality metrics, regardless of location or specialty.
CMS has developed a Virtual Groups toolkit to assist eligible physicians in understanding the ins and outs of this new structure.
Easier Alternative Payment Model (APM) participation
CMS is loosening some requirements for 2018 in an effort to seek larger participation in APMs. This includes exempting initial Comprehensive Primary Care Plus participants from the 50-clinician limit for organizations that can earn incentive payments via medical home models. CMS is also easing the requirement for medical home models to the minimum required amount of financial risk assumed by practices.
Looking for more information to help you witht MIPS/MACRA?
- How to develop your MIPS reporting strategy for 2018
- Navigating the Options: MIPS Success as a Service
Additional Resources about the Quality Payment Program: