The 2018 QPP Final Rule Has Arrived

Well, here it is! The 2018 Final Rule for the Quality Payment Program (QPP) was released on November 2nd, 2017 by the Centers for Medicare and Medicaid Services (CMS). Your performance in 2018 will affect your Medicare Part B payments in 2020. Able Health is here to help you navigate the expanding program.

Here are five highlights from the final rule, fresh off the press. You can also find additional points of comparison between 2017 and 2018 requirements below.

  • The Cost category will count for 10% of your MIPS score in 2018. The proposed rule had suggested that cost might once again count for 0% of your score in 2018, but it was finalized at 10%. Two cost measures will be used, Medicare Spending Per Beneficiary and Total Per Capita Cost. These measures will be calculated by CMS using administrative claims.
  • The threshold for avoiding the negative payment adjustment was increased from 3 Composite Performance Score points in 2017 to 15 points in 2018. This means that in 2018, submitting data for one measure will no longer enable you to avoid the penalty.
  • The Quality category will require 12 months of reporting for full participation in 2018, compared with a minimum of 90 days of data reporting in 2017.
  • New bonus points are available for showing improvement in the Quality category year over year, and for providing care for the treatment of complex patients. Complexity of patients will be based on a combination of Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated. Additionally, 5 bonus points will be automatically given to any clinician or group in a small practice (15 or fewer clinicians).
  • You can use either 2014 or 2015 Certified EHR Technology (CEHRT) for 2018 MIPS reporting, but a 10% bonus is available in the Advancing Care Information (ACI) category if you only use 2015 Edition CEHRT all year.

 

2018 Performance Category Breakdown

Here are the performance category weights for 2017 and 2018. The weights determine how much each performance category contributes to the Composite Performance Score, the number that matters for your reimbursement.

Category 2017 Performance Category Weight 2018 Performance Category Weight
Quality 60% 50%
Advancing Care Information 25% 25%
Improvement Activities 15% 15%
Cost 0%  10%

Key changes in requirements

 

Which requirements are increasing in 2018?

2017 Actual 2018 Final Comments
Total penalty and reward +/- 4% +/- 5% This increase is required by law.
Cost category contribution to the Composite Performance Score 0% 10% Performance will be calculated by CMS based on administrative claims.
Performance threshold to avoid a negative payment adjustment Composite Performance Score of 3 points Composite Performance Score of 15 points This is the number of points required to avoid a negative payment adjustment. The significant increase means that in 2018 it will no longer be possible to avoid a negative payment adjustment by reporting just one measure.
Data completeness requirement for quality measures 50% of patients across all payers 60% of patients across all payers This is an increase in the percentage of eligible patients required to be reported for each quality measure.
Quality reporting period 90 days 12 months The new 12-month reporting period mirrors PQRS requirements

 

Which requirements are staying the same in 2018?

2017 Actual 2018 Final Comments
ACI and Improvement Activities performance periods 90 days 90 days This is the minimum period you must report on for these categories to earn a maximum score.
Exceptional performance threshold Composite Performance Score of 70 points Composite Performance Score of 70 points This is the threshold above which you are eligible to earn incentive payments from the $500M bonus pool.
CEHRT Requirements 2014 certification required, 2015 certification optional 2014 certification required, 2015 certification optional (but with bonus points for use of exclusively 2015 CEHRT) This is different from the original expectation that 2015 EHR certification would be required in 2018. However, there is still a benefit for using a 2015 certified system due to the added bonus points.

 

Which requirements are relaxing in 2018?

2017 Actual 2018 Final Comments
Low-volume thresholds Clinicians or groups with ≤$30,000 in Part B allowed charges or ≤100 Part B beneficiaries are excluded from MIPS Clinicians or groups with ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries are excluded from MIPS This will mean that some clinicians and groups reporting in 2017 will not need to report in 2018.
Small practice bonus points Small practices (15 or fewer clinicians) do not earn additional bonus points Small practices automatically earn 5 bonus points in their final score as long as they submit data in at least one performance category This is an additional benefit for small practices to help them perform well in the program.
Bonus for providers with complex patient populations No bonus is given to clinicians and groups serving complex patient populations Clinicians and groups can earn up to 5 bonus points based on complexity of their patient population. Complexity of patients will be based on a combination of Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated.

 

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Further reading:
Radiology & MIPS Reporting: Everything You Need to Know
Help! I can’t find six relevant MIPS measures for my specialty

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