Assessing QPP Year 2's Final Rule

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In the last leg of 2017, CMS has issued the MACRA Quality Payment Program (QPP) final rule for year 2.

After gathering feedback during the lengthy comment period, Acting Administrator of CMS, Seema Verma said, "During my visits with clinicians across the country, I've heard many concerns about the impact burdensome regulations have on their ability to care for patients. These rules move the agency in a new direction and begin to ease that burden by strengthening the patient-doctor relationship, empowering patients to realize the value of their care over volume of tests, and encouraging innovation and competition within the American healthcare system."

As medical and health IT professionals across the country work to assess the 1,653-page published final rule, let's address key provisions.

MIPS Final Performance Categories
In calendar year 2018, the performance categories shift in weight to Quality at 50 percent, Improvement Activities at 15 percent, Advancing Care Information at 25 percent and Cost, the most significant change, moves to 10 percent of the final score. The final rule projects Cost to increase to 30 percent of the total MIPS performance score by the 2021 payment year.

Much to organizations like MGMA and CHIME's dismay, both Cost and Quality require a full year of reporting. The MIPS performance threshold increased as well from just three points in 2017 to 15 points in 2018. CMS is also finalizing changes to 27 existing Improvement Activities with plans to introduce an additional 21 to the inventory.

Exemption and Bonus Opportunities
For QPP year 2, the low-volume threshold for MIPS exemption stands at 200 Medicare patients, while the reimbursement threshold is $90,000 in Part B.

As seen in the proposed rule, year 2 allows up to five bonus points toward the MIPS final score for treating complex patients. Bonus is also possible under the Advancing Care category for providers solely using 2015 certified EHR technology (CEHRT). However, 2014-edition CEHRT is permitted; the bonus just does not apply.

CMS has made concentrated effort toward small practices, which are defined by MACRA as 15 eligible clinicians or fewer. Small practices can earn a bonus of five points toward the final MIPS score. A hardship exemption also applies under Advancing Care Information for MIPS, providing three points even if small practices submit quality measures below data completeness standards.

In light of recent natural disasters, year 2's final rule automatically weights the Quality, Advancing Care Information, and Improvement Activities performance categories at 0 percent for final score for those impacted by Hurricane Harvey, Irma, Maria or other natural disasters

MIPS Virtual Groups
As previewed in the proposed rule, QPP year 2 enables virtual group participation in the MIPS program. This is helpful for small practice clinicians, since they can team up for MIPS reporting on an aggregate basis, regardless of specialty or location. Those reporting under virtual groups must opt in by Dec. 31, 2017 for QPP year 2.

Advanced APMs
Under Advanced APMs, CMS extended the nominal amount standard of 8 percent until the 2020 performance year. The Medical Home Model holds a 2.5 percent risk with plans to gradually increase over time.

Starting in 2019, qualified payers (QPs) can leverage the All Payer Combination Option. An eligible clinician must participate in an Advanced APM with CMS as well as an Other Payer Advanced APM for this.

While most of the final rule's provisions were previewed in the proposed rule, the industry is still assessing how the 2018 plan will impact clinicians and their practices. Stay tuned for part II of our QPP year 2 final rule follow-up, discussing implications and tips for success.