On June 20, 2017, the Centers for Medicare and Medicaid Services (CMS) released a Notice of Proposed Rulemaking that includes changes to the Quality Payment Program for the 2018 calendar year. The Quality Payment Program, established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), began in 2017 under what CMS is calling a “transition year” for the program.
For the many providers in small practices who are still trying to understand the 2017 Quality Payment Program requirements, which include participation tracks for the Merit-Based Incentive Payment System (MIPS) and for Advanced Alternative Payment Models (Advanced APMs), proposed requirements for the 2018 calendar year may seem like too much information too soon. However, knowing what may be in store next year is one way physicians can try to stay ahead of the curve when facing the rapidly shifting healthcare regulatory environment. To help that cause, Practice Fusion has outlined five key takeaways from the CMS 2018 Quality Payment Program proposed rule below:
- CMS is committed to preserving independent clinical practices by helping providers in small practices succeed with value-based care. CMS has proposed several MIPS modifications that would make successful participation potentially more achievable for providers that participate in groups of 15 or fewer clinicians. For small practices, these modifications include additional bonus points being added to the MIPS Final Score, reduced data completeness requirements for quality measure reporting, and additional hardship exception opportunities related to the Advancing Care Information performance category.
- In 2018, MIPS will reward clinicians that use innovative technology to improve patient care. CMS has proposed bonus points for providers who exclusively use 2015 Edition Certified EHR Technology during the 2018 performance period, and will continue to offer bonus points to providers participating in end-to-end electronic reporting of quality measure data. CMS has also proposed adding an improvement activity that gives credit to providers who use evidence-based Appropriate Use Criteria decision support tools when ordering and furnishing advanced diagnostic imaging services for specific clinical conditions.
- The Quality performance category is still king under proposed MIPS scoring for 2018. For the 2018 performance year, CMS has proposed that the Quality performance category score under MIPS stay weighted at 60% and that the Cost performance category under MIPS stay weighted at 0%. CMS has also proposed that an additional 25% weight be added to the Quality performance category (using reweighting rules) for clinicians who use a hardship exception for the Advancing Care Information performance category.
- Clinicians participating in patient-centered medical homes have a path to Quality Payment Program success in 2018 and beyond. Clinicians and groups who have earned certification or recognition as patient-centered medical homes will automatically earn full credit towards the Improvement Activities performance category under MIPS. CMS has also proposed reducing the minimum total potential risk under the Medical Home Model Standard for 2018-2021, potentially making it easier for small practices to move into the Advanced APM participation track of the Quality Payment Program.
- Nothing proposed in this rule is a guarantee, and providing feedback to CMS through public comments is the best way to make sure your voice is heard. To provide feedback to CMS on the proposed Quality Payment Program changes and how they may impact your practice, submit comments before 5:00 PM (Eastern Time) on August 21, 2017. Comments may be submitted electronically starting on June 30th at http://www.regulations.gov and following the “Submit a comment” instructions for CMS-5522-P.
To learn more about what CMS has proposed for the Quality Payment Program in 2018, see the complete Notice of Proposed Rulemaking. To find out how Practice Fusion can help you participate in MIPS or Advanced APMs right now, visit the Practice Fusion Quality Payment Program Center.