The recently released CMS 2018 Quality Payment Program (QPP) final rule includes policies to reduce administrative burden for eligible clinicians participating in the Merit-based Incentive Payment System (MIPS).
Specifically, the final rule includes tailored flexibilities for small practices of 15 or fewer clinicians.
In a fact sheet highlighting the final rule’s new and modified policies, the federal agency stated it has been listening to provider feedback to ensure the program includes meaningful measures and activities, minimized clinician burden, improved care coordination, and clarity surrounding participation in advanced alternative payment models (APMs).
“Since January 1, 2017, we’ve worked with more than 100 stakeholder organizations and over 47,000 people to get the word out about the Quality Payment Program, get feedback, and help make it easier for you to participate,” stated CMS. “We’ve also reviewed over 1,200 stakeholder comments and are finalizing many of the proposed policies from the calendar year 2018 Quality Payment Program proposed rule.”
For eligible clinicians, CMS has built flexibilities into MIPS policies for the second year of QPP that resemble the transition year to help clinicians prepare for the third year of the program.
Specifically, the second year of QPP will proceed at a slow pace to assist clinicians in preparing for full implementation in year three and offer new incentives for program participation.
To ensure gradual implementation, CMS will weight the MIPS cost performance category to 0 percent of the total MIPS final score.
“We’re including the Medicare Spending per Beneficiary (MSPB) and total per capita cost measures to calculate your Cost performance category score for the 2018 MIPS performance period,” clarified the federal agency. “These two measures carried over from the Value Modifier program and are currently being used to provide feedback for the MIPS transition year.”
“CMS will calculate cost measure performance; no action is required from clinicians,” CMS continued.
Additionally, CMS will increase the performance threshold to 15 points in year two from three points during the transition year. The second year of QPP will also continue its phased approach to supporting QPP performance information on Physicians Compare.
“Just like in the transition year, we will keep offering our free, hands-on Technical Assistance to help you and your groups participate in the Quality Payment Program,” wrote CMS.
Furthermore, as part of the CMS Patients Over Paperwork initiative intended to reduce unnecessary regulatory burden and increase efficiency, the QPP final rule and comment period includes policies that exclude individual MIPS eligible clinicians with less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries.
As part of the initiative, CMS has also added a policy to address “extreme and uncontrollable circumstances,” such as hurricanes and other natural disasters. Additionally, the initiative will enable eligible clinicians to participate in virtual groups for year two.
The rule regarding “extreme and uncontrollable circumstances” includes a policy allowing eligible clinicians to submit hardship exemptions if they were unable to use certified EHR technology (CEHRT) as a result of a natural disaster.
This exemption will allow for the reweighting of the advancing care information performance category. Applications for this exemption are due December 31, 2017.
The federal agency also stated year two of QPP is designed to reduce burden by maintaining some slightly modified transition year rules, including the following:
- Raising the performance threshold to 15 points in Year 2 (from 3 points in the transition year).
- Allowing the use of 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2, and giving you a bonus for using only 2015 CEHRT.
- Giving up to 5 bonus points on your final score for treatment of complex patients.
- Automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the final score for clinicians impacted by hurricanes Irma, Harvey and Maria and other natural disasters.
- Adding 5 bonus points to the final scores of small practices
These modified rules from the transition year are intended to offer clinicians more ways to successfully participate in the program.
For small practices including 15 or fewer physicians, the QPP final rule will add 5 bonus points to their final scores, offer solo practitioners and small practices the choice to form or join virtual groups to participate with other practices, and continue to award small practices three points for measures in the quality performance category that do not meet data completeness requirements.
Additionally, CMS has added a new hardship exception for the advancing care information performance category for small practices.
There are also policies in the second year of QPP aimed at implementing provisions in the 21st Century Cures Act. Specifically, CMS will reweight the advancing care information performance category to 0 percent of the final score for ambulatory surgical centers-based MIPS eligible clinicians.
The Cures Act will also be used to allow for significant hardship exceptions and for hospital-based MIPS eligible clinicians to reweight the advancing care information performance category to 0 percent of the final score.
Finally, CMS will allow for eligible clinicians to participate in MIPS through virtual groups.
“A Virtual Group is a combination of 2 or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter specialty or location) to participate in MIPS for a performance period of a year,” clarified CMS.
These changes to MIPS should reduce administrative burden on providers and allow for more successful participation in the second year of QPP. The final rule also includes a comment period to allow for continued stakeholder feedback.