A proposed rule updating the Medicare Quality Payment Program (QPP) was released on June 30, 2017, by the Centers for Medicare and Medicaid Services (CMS). While changes were recommended to both tracks of the QPP (Advanced APMs and Merit-Based Incentive Payment System [MIPS]), we will highlight those affecting MIPS since more physicians will participate in that track, at least in the initial years of the program.
Low Volume Threshold
Among the biggest proposed changes is increasing the low-volume threshold to exclude individual MIPS eligible clinicians or groups with ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries. For year one, the threshhold was ≤$30,000 in Part B allowed charges or ≤100 Part B beneficiaries.
Also, starting with 2019 MIPS performance period, CMS is proposing to let clinicians opt-in to MIPS if they exceed 1 or 2 of the low-volume threshold components. CMS also proposed adding the number of Part B items and services as a 3rd low-volume threshold component.
Virtual Groups
Another important change to the program for the 2018 performance year (2020 payment year) is the addition of the Virtual Groups participation option. Virtual Groups would comprise solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” with at least one other such solo practitioner or group to participate in MIPS for a performance period of a year.
Clinicians in a Virtual Group would report as such across all four performance categories and would need to meet the same measure and performance category requirements as non-virtual MIPS groups. Participants in a virtual group must surpass the low-volume threshold individually in order to participate and must elect the MIPS virtual group option prior to the beginning of the performance period. Once the performance period starts, they are locked into that option. As well, all MIPS eligible clinicians within a TIN must participate in the virtual group.
Other Proposed Changes
Here are a few other proposed changes to MIPS grouped by topic:
Performance Period Requirements
- Increasing the performance period requirements to include a full year of data for the Quality and Cost performance categories, though CMS would not use Cost performance scores for final score determination in 2018/2020.
- Increasing the performance period to 90-days of data for the Improvement Activities and Advancing Care Information performance categories.
Bonus Points
- Continuing to allow the use of 2014 Edition CEHRT (Certified Electronic Health Record Technology) in 2018, while encouraging the use of 2015 edition CEHRT through bonus points for using 2015 Edition CEHRT exclusively.
- Adding bonus points in the scoring methodology for caring for complex patients.
Facility-Based Scoring
- Implementing an optional voluntary facility-based scoring mechanism based on the Hospital Value Based Purchasing Program. Available only for facility-based clinicians who have at least 75% of their covered professional services supplied in the inpatient hospital setting or emergency department. The facility-based measurement option converts a hospital Total Performance Score into a MIPS Quality performance category and Cost performance category score.
Submission Mechanisms
- Allowing individual MIPS eligible clinicians and groups to submit measures and activities through multiple submission mechanisms within a performance category as available and applicable to meet the requirements of the Quality, Improvement Activities, or Advancing Care Information performance categories.
Scoring and Payment Adjustments
- Incorporating MIPS performance improvement in scoring quality performance.
- Allowing the Cost category to be weighted with 0% for 2018/2020 (rather than 10% as previously mandated), and increasing Quality from 50% to 60%.
- Payment adjustments increase to 5% from 4% in 2017/2019.
Small Practices
- Adding a new hardship exception for clinicians in small practices under the Advancing Care Information performance category.
- Adding bonus points to the Final Score of clinicians in small practices (defined in the regulations as 15 or fewer clinicians) by adding 5 points to the final score, as long as the eligible clinician or group submits data on at least 1 performance category in an applicable performance period.
- Continuing to award small practices 3 points for measures in the Quality performance category that don’t meet data completeness requirements. (Larger practices will be limited to 1 point for measures that don’t meet data completeness requirements.)
21st Century Cures Act
- Reweighting the Advancing Care Information performance category to 0% of the final score for ambulatory surgical center (ASC)-based MIPS eligible clinicians.
- Using the authority that the 21st Century Cures Act grants CMS to allow for significant hardship exceptions for hospital-based MIPS eligible clinicians in the Advancing Care Information performance category.
Comments on the proposed rule must be submitted by the close of the 60-day comment period on August 21, 2017. Instructions for submitting comments can be found in the proposed rule. When commenting refer to file code CMS 5522-P.
For more information, review the following:
- Proposed Rule for Quality Payment Program Year 2 Fact Sheet
- Full draft of the Proposed Rule for Quality Payment Program Year 2
- CMS Listening Session Slides on the Proposed Rule for the Quality Payment Program Year 2
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