On Nov. 2, 2017, CMS published its final rule implementing the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act (MACRA). The final rule, which has a comment period through Jan. 1, 2018 and provides updates for QPP’s second (2018) and future years, reflects what some see as an effort to address physicians’ concerns about regulatory burdens.
MIPS Survives: Will Your Practice Thrive?
Our first post in this series addressed MACRA’s two tracks for quality-based payments to physicians who treat Medicare fee-for service patients—the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (A–APMs). Our second post asked whether MIPS would survive in its present form in the final rule. It does.
CMS says it estimates that approximately 622,000 eligible clinicians will be subject to MIPS reporting requirements and payment adjustments in the 2018 MIPS performance period. The final rule’s exemption of providers with less than $90,000 in Part B charges or less than 200 beneficiaries in their care is somewhat of a relief for small practices.
According to the final rule, your MIPS final score will be made up of:
- 50 percent based on quality performance (report for entire year)
- 25 percent on advancing care information (90 days of reporting)
- 15 percent on improvement activities (90 days of reporting)
- 10 percent on cost performance (report for entire year)
The agency initially proposed not to count the cost category at all for 2018, but the MACRA statute requires that component to account for 30 percent of MIPS in 2019, and CMS concluded it best to ease into that transition,” according to Health Affairs. “Nine new quality measures were adopted, including those relating to back pain and developmental screening and wellness visits for children. Additional changes were made to the sets of metrics specialists may report on and patient satisfaction measures. CMS raised the bar for the completeness of reporting on quality measures from 50 to 60 percent.”
Addressing smaller practices’ concerns about being able to participate in the QPP, CMS added the following “flexibilities” for 2018:
- Implementation of the virtual groups provisions
- Increase in the low volume threshold to less than or equal to $90,000 in Medicare Part B allowed charges or less than or equal to 200 Medicare Part B patients
- Addition of a significant hardship exception from the advancing care information performance category for MIPS eligible clinicians in small practices
- Provision of 3 points even if small practices submit quality measures below data completeness standards
- Option to get bonus points added to the final scores of MIPS-eligible clinicians who are in small practices
Interested in Joining a Virtual Group? Act Quickly
MACRA provides three ways to participate in MIPS and report information: on an individual, group and virtual group basis. As noted in a previous post, virtual groups are attractive to smaller practices because of the option to pool resources.
The final rule “creates new avenues for solo practitioners and small practices to participate and succeed under MIPS—but time is of the essence,” according to the Health Data Management blog. “Solo practitioners and small practices can form a virtual group without specialty or location limitations to participate in MIPS together.” CMS has made a toolkit available for virtual groups, but the deadline is coming up quick, on Dec. 1, 2017.