Low-volume exclusion: CMS has significantly broadened the MIPS low-volume exclusion. MIPS will not apply to individual clinicians or groups with $90,000 or less in annual Medicare revenues or 200 or fewer Medicare patients. As a result, CMS estimates that only 37% of physicians will be subject to MIPS. CMS has, however, declined to allow low-volume clinicians the right to opt-in to MIPS so those who meet the exclusion criteria cannot participate even if they would like to. CMS is considering an opt-in opportunity for future years.
Special rules for small practices: Allergists practicing in small groups of 15 or fewer clinicians will get additional breaks under MIPS including:
- An automatic bonus of 5 points to the MIPS score
- A hardship exception from the Advancing Care Information category of MIPS (formerly “meaningful use”).
- Favorable scoring under MIPS quality category even if they do not meet data completeness standards.
- The option of joining together with other practices to create virtual groups.
CMS has also made some changes to the scoring for the four MIPS categories: Quality, Cost, Advancing Care Information, and Improvement Activities.
Quality reporting (formerly PQRS)
- Quality measures will count for 50% of the MIPS score in performance year 2018, down from 60% in 2017.
- Clinicians must still report at least 6 measures and must report outcomes measures if available.
- Measures must be reported for an entire 12 months.
- For the allergy/immunology specialty measure set, outcome measures have been removed although those measures can still be reported separately rather than as part of the set.
Advancing care information (formerly “meaningful use”)
- Small practices (15 or fewer clinicians) can get a hardship exception to this category. This means this performance category will count for 0% of the MIPS score and the 25% it would otherwise count for, is reallocated to the quality category. Practices will have to request the exception but it will be granted automatically upon request.
- Clinicians can use either the 2014 or 2015 edition of CEHRT – but there is 10% bonus for using the 2015 edition.
- Reporting must be for at least 90 days of the year.
Improvement activities
- Compliance with improvement activities can be established through attestation.
- Points for clinical practice improvement activities are doubled for small practices.
- Clinicians need only report for 90 days.
Cost category
- This category will constitute 10% of the MIPS score in performance year 2018, up from zero in 2017.
- Cost scores will be based on total patient cost and total spending around a hospital admission – both of which the Advocacy Council opposed. CMS is developing new episode-based cost measures – with input from the specialties – that will be rolled out sometime in the future.
More information about the 2018 policies can be found on the CMS QPP website.