On June 20, 2017, The Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) proposed rule, which proposes policies for the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) programs 2018 to impact 2020 Medicare physician payments.
It doesn’t seem that long ago when MACRA was first announced and the final rule was released last October. But now, providers are anticipating what’s ahead for the program in its second year, especially for the Quality Payment Program. The healthcare industry received its first glance at what’s in store for 2018 as CMS released the QPP proposed rule earlier this week.
What changes mean for Providers?
More solo practitioners and small groups will be excluded from the Merit-based Incentive Payment system (MIPS) in 2018; those remaining in the program will need to prepare for increased reporting requirements. Simultaneously, many healthcare organizations will need to begin defining a broader value-driven care strategy, and considering how to structure contracts with non-Medicare payers.
CMS will accept comments on the proposed rule until August 18, 2017, and the Final Rule will be published in the fall.
MIPS Transition Reporting and Scoring Thresholds
CMS proposes a continuation too many of its initial transition year policies in 2018 and to moderately increase the thresholds for MIPS eligible clinicians from the 2017 performance year. This includes:
- Increasing the performance threshold from three points to 15 points in 2018 and maintaining the additional performance threshold at 70 points.
- Slightly increasing data completeness thresholds for most reporting mechanisms within the Quality category from 50 percent in 2017 to 60 percent in 2019 and continuing to implement scoring floors.
- Increasing the performance period to a full calendar year for the quality category in 2018, while keeping the performance periods for Improvement Activities and Advancing Care Information at 90 days.
Highlights from the QPP Proposed Rule
- 2018 will feature continuation of “pick your pace” for the new payment system’s data reporting and expands exemption of physicians from mandatory participation.
- Physicians will be able to participate in MIPS through Virtual Groups working with other small practices to combine their administrative costs.
- Physicians in small practices will receive extra “bonus” points within the Composite Performance Score for MIPS to recognise their value to communities where they practice.
MIPS Cost Performance Category Delay
The cost performance category has been a significant concern for clinicians and provider groups of all sizes and as a result, CMS proposed to eliminate the domain for an additional year.
Changes to the Cost category proposed by CMS include:
- Measuring clinicians on Medicare Spending per Beneficiary (MSPB) and total per capita cost measures. However clinicians will not be scored on these in 2018.
- Eliminating the previously finalized 10 episode-based measures and continuing to work with stakeholders on replacing these measures.
Virtual Groups in 2018
Beginning in 2018, solo practitioners and groups of 10 or fewer will be able to partner virtually with other solo practitioners or groups of 10 or fewer, regardless of location or specialties. They will generally be treated as any other group in the QPP. This could be an attractive option for clinicians who may not have the resources to perform well in the QPP independently.
All-Payer Combination Advanced APM Option
Alternative Payment Model (Advanced APM) track by participating in a combination of Medicare and other payer models. In its 2018 proposed rule, CMS provides the first details of the All-Payer Combination methodology which will be used to shape contracts with non-Medicare payers over the next several years. Key provisions include:
- Determining Qualifying Participants under the All-Payer Combination Option at the individual clinician level only.
- Allowing clinicians to self-submit other payer data to CMS without requiring that payers attest to this data.
- Implementing an eight percent revenue-based threshold in addition to the existing benchmark-based total risk threshold, similar to the finalized Medicare nominal amount standard
For more information or to discuss implications for your organization, please contact us.