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Quality & Practice

2018 Quality Payment Program Proposed Rule

Background

On June 21, 2017 the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would make changes in the second year of the Quality Payment Program as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS’s goal is to simplify the program, especially for small, independent, and rural practices, while ensuring fiscal sustainability and high-quality care within Medicare.

Support from Your Academy

Your Academy has been diligently reviewing the proposed rule. Below is what we know so far, including a win for physiatry!

Additional accommodations for small practices

  • Significantly expands the low-volume threshold to $90,000 or less in Medicare Part B allowed charges OR 200 or fewer Medicare Part B patients (previously the threshold was $30,000 in allowed charges or 100 patients) – CMS estimates that only 37% of clinicians who bill Medicare will be subject to MIPS;
  • Creates virtual groups to assist small practices;
  • Adds 5 bonus points to the final MIPS scores for practices of 15 or fewer clinicians; and
  • Adds a hardship exception from the Advancing Care Information (previously Meaningful Use) category for practices of 15 or fewer clinicians.

Quality

  • Increases the quality performance category weight to 60% in 2018 (due to the Cost category weight remaining at zero in 2018); and
  • WIN FOR PHYSIATRY: In the Spring of 2017, your Academy had discussions with CMS officials regarding measures in the Physical Medicine Specialty Set that were difficult to report due to coding issues or data submission methods. We are happy to see in the proposed rule, that CMS listened and one of the measures, Closing the Referral Loop: Receipt of Specialist Report, has been updated for 2018 reporting. Your Academy will look for further information from CMS on the other measures discussed. 

Advancing Care Information

  • Allows the use of 2014 edition certified electronic health records technology (CEHRT) past 2017 – CMS will not mandate that physicians update their EHRs in 2018; and
  • Increases opportunities for bonus percentage points.

Improvement Activities 

  • CMS continues to allow physicians to report on IAs through simple attestation; and
  • The proposed rule creates stability in program requirements by not changing the number of IAs physicians must report.

Cost Category

  • CMS proposes a zero weight for costs again in the 2018 performance/2020 payment year, which would rise to 30% the following year; and
  • 10 previously-finalized episode-based cost measures will be replaced in the future with measures developed with more input from clinical experts and stakeholders. Dr. Andrew Gordon and Dr. Kirk Whetstone represent the Academy on this CMS technical expert panel.

Alternative Payment Models

  • The revenue standard for more than nominal financial risk remains at 8% of revenues; and
  • The Physician-focused Payment Model committee may consider APMs for which Medicaid is a payer even if Medicare is not.

Your Academy will continue to review the proposed rule over the next month and a half. Comments are due to CMS on August 21, 2017. Keep checking this website for more information on the proposed rule and email us at healthpolicy@aapmr.org with any questions.

Learn More

  • Learn more about the 2018 Proposed Rule with this CMS Fact Sheet
  • Learn more at the 2017 AAPM&R Annual Assembly with a dedicated MIPS session
  • Learn more about the 2017 Quality Payment Program in Your Academy's Action Kit
  • Learn more about 2017 MIPS reporting
  • Learn more about 2017 APMs reporting