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CMS Releases Proposed Quality Payment Program Rule Summary

In preparation for public comment, CMS has published a summary of its Quality Payment Program proposed rule

MACRA Implementation

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By Kate Monica

- CMS recently released an extensive 26-page summary of the Quality Payment Program (QPP) proposed rule detailing the most significant potential changes providers can expect should the rule go into effect.  

QPP was designed primarily to improve health outcomes, reduce spending and administrative burden, and offer providers a fair and transparent payment system. However, the advent of the value-based payment system has caused some clinicians—specifically those working in small or rural practices—significant administrative strain due to stringent reporting requirements. 

In response, CMS collected feedback from over 100 stakeholder organizations and over 47,000 individuals to help clinicians prepare to participate in QPP and devise potential changes to program policies.

CMS established the following transition year policies in response to clinician feedback: 

  • Giving clinicians the option to choose how they’ll participate. (For the 2017 transition year, MIPS eligible clinicians have the opportunity to “pick their pace” of participation in the performance period by submitting a minimum amount of data, 90-days of data, or a full year of data.)
  • Having a low-volume threshold that exempts many clinicians with a low volume of Medicare Part B payments or patients.
  • Allowing flexibilities for clinicians who are considered hospital-based or have limited face-to-face encounters with patients (referred to as non-patient facing clinicians). 

CMS aims to further minimize administrative burden, improve care coordination for patients, and support a pathway for providers participating in Advanced APMs in 2018.

Additionally, the second year of QPP will employ a ‘pick your pace’ strategy to promote flexibilities and allow for clinicians to more easily participate and prepare for full implementation.

“Some prominent proposals include modestly increasing the performance period requirements to include a full year of data for the Quality and Cost performance categories, though CMS would not use Cost performance scores for final score determination,” stated the federal agency.

CMS also proposed extending the performance period to 90 days for the Improvement Activities and Advancing Care Information performance categories.

Other proposals part of the modified QPP rule include: 

  • Offering the Virtual Groups participation option.
  •  Increasing the low-volume threshold so that more small practices and eligible clinicians in rural and Health Professional Shortage Areas (HPSAs) are exempt from MIPS participation.
  • Continuing to allow the use of 2014 Edition CEHRT (Certified Electronic Health Record Technology), while encouraging the use of 2015 edition CEHRT.
  • Adding bonus points in the scoring methodology for caring for complex patients and using 2015 Edition CEHRT exclusively
  • Incorporating MIPS performance improvement in scoring quality performance.
  • Incorporating the option to use facility-based scoring for facility-based clinicians.
  • Additionally, CMS proposed the following flexibilities specifically to assist small practices:
  • Add a new hardship exception for clinicians in small practices under the Advancing Care Information performance category.
  • Add bonus points to the Final Score of clinicians 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 also proposed adding a new improvement activity for MIPS eligible clinicians to choose if they are using Appropriate Use Criteria (AUC) for ordering advanced diagnostic imaging services.

Another proposed rule the federal agency seeks to enact would reweight the Advancing Care Information performance category to 0 percent of the final score for ambulatory surgical center (ASC-based MIPS eligible clinicians.

At the close of its summary, CMS included a table displaying the side-by-side differences between the current transition year and the proposed policies for the second year of QPP.

The over 400-page proposed rule has already garnered support from organizations such as AHA and HIMSS and will be open for public comment until August 21, 2017. 

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