The final rule for the second year of the Medicare Access and CHIP Reauthorization Act (MACRA)’s Quality Payment Program (QPP) takes important steps toward acknowledging the challenges and concerns voiced by stakeholders regarding the ability of some clinicians to meet QPP reporting requirements. In particular, CMS is continuing to transition slowly and offering new incentives for participation.
For instance, the 2018 final rule continues the “pick your pace” option under the Merit-Based Incentive Payment System (MIPS), which was established in the QPP implementation policy for 2017 and allows clinicians to choose their level of participation in the program, granting some additional breathing room to those still struggling to meet the QPP requirements.
The final QPP rule also eases the burden for small practices, exempting physicians from MIPS participation if they have less than or equal to $90,000 in Part B allowed charged or see fewer than 200 Part B patients for 2018. As a result of this change, only 40% of all clinicians who bill Medicare will be subject to MIPS participation. In addition, solo practitioners and small practices will have the ability to form or join virtual groups so that they have a better chance of meeting eligibility requirements for the MIPS bonus.
Of concern to many physicians following finalization of the 2017 QPP rule was the policy that physicians would be required to use only the 2015 edition of Certified EHR Technology (CEHRT), despite the fact few electronic health record vendors meet the 2015 CEHRT criteria. The final 2018 QPP rule continues to allow physicians participating in MIPS to use either the 2014 or 2015 CEHRT for 2018.
The agency has also made it easier for clinicians to participate in select Advanced Alternative Payment Models (advanced APMs), including extending the 8% “risk standard” through performance year 2020 and making it easier for clinicians to qualify for incentives for participation in APMs that begin or end in the middle of the year.
A full overview of the changes and updates addressed in the 2018 final rule are available here. CMS released this interim final rule with public comment; they will accept public comment on the final rule until 5:00 p.m. ET on January 1, 2018.
To learn how healthcare providers are getting ahead of the QPP curve by leveraging data-driven analytics to better assess quality performance, understand opportunities for improvement and support quality reporting efforts, read part 3 of this series.
For more on the challenges of implementing MACRA and how the final QPP rule addresses them, read part 1 of this series.