BMN Blog

On June 20^th, CMS issued its proposed rule for year 2 of the Quality Payment Program (QPP) under Medicare Access and CHIP Reauthorization Act of 2015( MACRA).  Comment period ends August 20. 

Quality, cost and performance is measured by QPP through two optional paths: (1) Merit-based Incentive Payment System (MIPS) consolidating meaningful use and other physician quality reporting programs and providing negative, neutral or positive payment adjustments to Medicare Part B payments or (2) participation in Advanced Alternative Payment Models (AAPMs) which offers bonuses and higher annual fee updates. Nonqualifying APM Clinicians may participate in a MIPS-APM with modified reporting requirements. 

CMS’s Administrator Seema Verna stated, “ By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork. CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.” The proposed changes are of particular benefit to small and rural practices and Medical Home and CPC+ models.  CMS expects proposed low volume threshold and APM changes will increase clinicians exempt from MIPS evaluation from the 806,879 in 2017 to approximately 941,000 in 2018.  

MIPS proposed changes:

• For small or rural practices, increased low-volume threshold exemption. Clinicians with a low volume of Medicare Part B payments (≤ $90,000) or patients (≤ 200) will be exempt from evaluation under MIPS. The proposed rule also offers Virtual Group participation; adds a new Advancing Care Information (ACI) hardship exception; adds bonus points to the final score; and assigns 3 points to Quality for measures that do not meet completeness (as opposed to 1 point).
• Bonuses: caring for complex patients, using 2015 CEHRT, additional registry reporting, 5 point bonus for small and rural practices
• For ASCs, re-weights the ACI category to 0% of the final score for ASC based MIPS-eligible clinicians
• Non-patient facing determination will apply to Virtual Groups
• Facility-based clinicians (> 75% services inpatient or ED) will be able to participate using facility-based measures based on the Hospital Value Based Purchasing Program which converts the hospital Total Performance Score (TPS) into a MIPS score.
• Continues 0% weight for Cost category through 2020
• Offers continued use of 2014 CEHRT in ACI category
• New MIPS performance improvement scoring for quality and cost performance; potential additional 10 points for improvement over prior year’s score
• Includes CPC+ in patient-centered medical home definition
• Thresholds: payment ≥ 15; exceptional performance ≥ 70
• Performance period: calendar year for quality and cost; 90 days for ACI and Improvement Activities

In addition to changes under MIPS, CMS proposes changes to APMs and MIPS-APMS such as extending nominal risk levels through 2020, offering changes of particularly significant advantage to CPC+ and Medical Home Models, offering All-Payer combination options, providing an additional “snapshot” date for MIPS APM participation determination and permitting Virtual Group MIPS APMs to receive their MIPS payment adjustment based on the APM entity score.