Need to Know: Highlights from the 2018 QPP Proposed Rule and What It Means for You

Today, CMS released the proposed rule for the 2018 Quality Payment Program. In the past few months speculation has abounded: what will the new political climate mean for the QPP? How will the experience in year 1 affect year 2 implementation? Here, we give you the most important high-level takeaways from the proposed rule (and remember, nothing will be final until the fall!). Stay tuned for deep dives into the the proposed rule from Able Health in the coming days and weeks.

1. The QPP is here to stay

There are significant changes in the new proposed rule relative to the 2018 plans laid out in the final rule governing the 2017 performance year, but the backbone of the program is the same. Core program elements, such as performance categories and the structure of the program tracks, remains unchanged. In addition, continued program advancements, such as increasing reporting requirements, are being proposed as expected, some of which we will discuss below.

What this means for you: It is not time to pump the breaks on MIPS, but rather you can feel comfortable setting up systems to succeed in this program as it expands in the future.

2. The Cost category may not be included in your final score again in 2018

CMS has proposed that cost will again account for 0% of the composite performance score in 2018 and not impact payments in 2020, though this is only a proposal, and CMS is requesting feedback on this aspect. As a result, the category weights would stay the same in 2018 as they did in 2017, with Quality counting for 60%, Advancing Care Information counting for 25%, and Improvement Activities counting for 15%.

What this means for you: You may not need to focus as heavily on Cost in 2017 and 2018, except to prepare for the likely inclusion of Cost in your Composite Performance Score in 2019.

3. There will likely be more flexibility for small practices

CMS is proposing increased thresholds for low volume exclusions in 2018 relative to 2019. As opposed to the 2017 thresholds, where clinicians or groups with ≤$30,000 in Part B allowed charges or ≤100 Part B beneficiaries will be excluded for low volumes, CMS is proposing thresholds of ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries.

What this means for you: if you are an eligible clinician or group with a comparatively small of Medicare Part B patients but were not excluded from MIPS in 2017 (you can check here), you may be excluded in 2018.

4. There may be additional bonus points available

CMS has proposed adding additional bonus points to increase flexibility and reward clinicians and groups who have more difficulty scoring well in MIPS:

  • There may be up to 10 percentage points available for performance improvement in the Quality category. This bonus will be based on the rate of improvement in the Quality category score between the 2017 performance year and the 2018 performance year.
  • There may be an additional bonus of up to 3 points available for eligible clinicians based on the medical complexity of patients they see. The assessment of medical complexity may be based on the average Hierarchical Conditions Category (HCC) risk score.
  • There may be a bonus of 5 points automatically awarded to any eligible clinician or group in a small practice with 15 or fewer clinicians.

What this means for you: if you are an eligible clinician or group who has difficulty scoring well in MIPS, whether due to small size, complexity of your patient population, or other reasons, there may be additional help for you in 2018

5. There will likely be an opportunity to join a Virtual Group

Virtual Groups will be comprised of eligible clinicians in solo practices or groups of 10 or fewer clinicians who elect to jointly participate in MIPS. These small practices be able to join together across TINs to create a single group for the purposes of MIPS reporting.

What this means for you: If you are a solo practitioner or small group, this gives you flexibility to join together with other clinicians who are in the same or different specialties, or the same or different geographies. You will need to elect to participate in a Virtual group in 2018 prior to the start of the 2018 performance period.

Sign up for our newsletter to stay informed as new information about the 2018 Quality Payment Program performance period becomes available.

Further reading:
6 ways to improve MIPS quality performance with the data you already have
MIPS exceptional performance bonus: how much could you earn?

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