New Proposed Rule for Quality Payment Program 2018

As the Quality Payment Program approaches its second year in 2018, the Centers for Medicare & Medicaid Services (CMS) are proposing several changes and updates in an effort to improve patient outcomes, increase coordination of patient care, reduce the burden on small and rural practices, while increasing participation and program flexibility. The goal is to keep what is working with the program and use clinician feedback to improve policies.

A few of the changes proposed by CMS are as follows:

• Increasing the performance period to 90-days of data for the Improvement Activities and Advancing Care Information performance categories.
• Offering the Virtual Groups participation option. Virtual Groups. CMS defines a virtual group as two or more practices with 10 or fewer providers each that combine their performance for the full year reporting period. This option allows providers who are MIPS-exempt to participate in MIPS through their Virtual Group and receive bonus payments.
• Increasing the low-volume threshold to ensure more small practices and eligible providers in rural areas are exempt from MIPS participation. CMS proposed raising the threshold from 100 to 200 Medicare Part B beneficiaries, and from $30,000 to $90,000 in Medicare Part B charges annually.
• CMS will continue to allow 2014 Edition CEHRT (Certified Electronic Health Record Technology) while encouraging the use of 2015 edition CEHRT.
• New bonus points will be added to the scoring methodology for:
  • Caring for complex patients
  • Using 2015 Edition CEHRT exclusively
• Small practices
• Incorporating MIPS performance improvement in scoring quality performance.
• Implementing the option to use facility-based scoring for facility-based clinicians.

CMS is proposing more flexible options for providers in small practices that would:

• Add a new exception for providers in small practices under the Advancing Care Information performance category.
• Add bonus points for providers in small practices.
• Continue to award small practices 3 points for measures in the Quality performance category that don’t meet data completeness requirements

CMS is also proposing the following changes and updates:

• Extending the revenue-based nominal amount standard through 2020. This allows an APM to meet the financial risk criterion to qualify as an Advanced APM if participants bear a total risk of at least 8% of their Medicare Parts A and B revenue.
• Changing the nominal amount standard for Medical Home Models so that the amount of total risk slowly increases annually.
• Provide more details on the All-Payer Combination Option. This option allows providers to become Qualifying APM Participants (QPs) through a combination of Medicare participation in Advanced APMs and participation in Other Payer Advanced APMs. This option will be available in 2019.
• Provide more detail on how eligible providers participating in selected APMs will be assessed under the APM scoring standard. This standard reduces burden for certain APMs (MIPS APMs) participants who do not qualify as QPs, and are therefore subject to MIPS.

For more information regarding the proposed rule for the Quality Payment Program 2018 visit:

https://qpp.cms.gov/docs/QPP_Proposed_Rule_for_QPP_Year_2.pdf