The Centers for Medicare and Medicaid Services (CMS) recently released the final Quality Payment Program (QPP) policies for the Merit Incentive Payment System (MIPS) and the Alternative Payment Model (APM) programs. These rules will govern performance in 2018 and payments made in 2020. Overall, the new rules are much more flexible and less burdensome than previous policy. Here are some of the highlights:
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.
