CMS Finalizes Updates to Quality Payment Program for 2018
The Centers for Medicare & Medicaid Services (CMS) issued, Nov. 2, a final rule with comment period for payment and policy updates to the Quality Payment Program (QPP) in 2018 and beyond. Conjointly, CMS issued an interim final rule with comment period to address the extreme and uncontrollable circumstances that occurred this year, which may have impeded affected clinicians’ performance in the Merit-based Incentive Payment System (MIPS).
Overview of MIPS
In the 2018 Quality Payment Program final rule, CMS is finalizing for MIPS:
- Policy for virtual groups.
- An increase in the low-volume threshold (less than or equal to $90,000 in Medicare Part B allowed charges or less than or equal to 200 Medicare Part B patients).
- A 5-point bonus to final score for MIPS eligible clinicians in groups, virtual groups, or alternate payment model (APM) entities that have 15 or fewer clinicians and submit data on at least one performance category in 2018.
- The proposal to allow clinicians to use facility-based measurement in year three (2019) of the QPP.
- A complex patient bonus capped at 5 points using the dual eligibility rationale and average hierarchy condition category (HCC) risk score. The final score will be compared against the MIPS performance threshold of 15 points for the 2020 payment year.
Quality Performance Category
- The Quality performance category will be worth 50 percent for the MIPS 2020 payment year, instead of the proposed 60 percent.
- The data completeness threshold will be 60 percent for data submitted on quality measures using qualified clinical data registries (QCDR), qualified registries, certified electronic health record technology (CEHRT), or claims for the 2020 and 2021 payment years.
- For quality data submitted via CEHRT, QCDR, or qualified registry, the number of points available for measures that do not meet the data completeness criteria is 1 point; however, there is a 3-point guarantee for small practices that submit any data, regardless of quality.
Improvement Activities (IA)
- The weight for the IA performance category will continue to be 15 percent of the final score.
- CMS will no longer require self-identifications for non-patient-facing clinicians.
- Participants must submit data on IA via qualified registry, CEHRT, QCDR, CMS Web Interface, or attestation. Clinicians must submit a “yes” response for activities that are performed for at least a continuous 90 days.
- There are 21 new improvement activities and changes to 27 previously adopted improvement activities (see Tables F and G in the final rule).
- For the 2021 MIPS payment year, the 2019 performance period for the IA category is a minimum of a continuous 90-day period.
- CMS is expanding the definition of a certified patient-centered medical home (PCMH): At least 50 percent of the practice sites with the tax identification number (TIN) must be recognized as a PCMH to receive full credit. CMS defines a “practice site” as the physical location where services are delivered.
Advancing Care Information (ACI)
- The weight for the ACI performance category remains 25 percent (30-75 percent for clinicians participating in a MIPS APM).
- For the 2021 payment year, the performance period for ACI is a minimum of a continuous 90-day period in 2019.
- Participants may continue to use EHR technology certified to the 2014 or 2015 edition or a combination of the two. Participants can earn a bonus for using only 2015 edition software in 2018.
- Exclusions may apply for the e-Prescribing and HIE objectives in 2018.
- Eligible clinicians can earn 10 percentage points for reporting to any single public health agency or clinical data registry to meet any measure associated with the Public Health and Clinical Data Registry Reporting objective; receive an additional 5-point bonus for reporting to more than one.
- The new deadline for submitting a hardship exception application to request the re-weighting of the ACI category is Dec. 31, beginning in 2018.
- CMS is adding improvement activities that are eligible for a 10 percent bonus under the ACI if completed using CEHRT.
- Groups considered to be non-patient facing (more than 75 percent of the national provider identifiers (NPI) billing under the group’s TIN meet the definition of a non-patient facing individual MIPS eligible clinicians) will automatically have their ACI re-weighted to zero.
CMS is finalizing a 10 percent weight for the Cost performance category using Total Per Capita Costs for All Attributed Beneficiaries measure and the Medicare Spending Per Beneficiary (MSPB) measure, rather than the 10 episode measures previously adopted. Look for performance feedback on these measures by July 1, 2018.
2018 policy changes for virtual groups and APMs will be covered in separate articles.
Interim Final Rule with Comment Period (IFC)
To account for hurricanes Harvey, Irma, and Maria, CMS is establishing an automatic extreme and uncontrollable circumstance policy for the Quality, IA, and ACI performance categories for the 2017 MIPS performance period. CMS will apply the policy to MIPS eligible clinicians without requiring an application when CMS determines a triggering event has occurred and the clinician is in an affected area. CMS will automatically weight the Quality, IA and ACI categories to zero percent of the final score, resulting in a final score equal to the performance threshold, unless the clinician submits data, which CMS would then score as usual.
Check back on AAPC’s Knowledge Center for more details on this final rule, forthcoming.