CMS releases final rule for the Quality Payment Program: 4 things you need to know for participating in 2017

Today the Centers for Medicare and Medicaid Services (CMS) released the highly anticipated final rule that will implement the Quality Payment Program (QPP) as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Here are four things you need to know about the final rule as it relates to participation in 2017:

Eligible clinicians can choose their pace of participation

Although the QPP will still begin January 1 2017, there will be a ramp-up period with less financial risk for eligible clinicians in at least the first two years of the program. Given the wide diversity of clinical practices, the initial development period of the QPP implementation would allow clinicians to pick their pace of participation for the QPP’s first performance period that begins January 1, 2017. As described by CMS in the final rule:

A low-volume threshold will help exempt certain small practices from the new requirements. For 2017, small practices can be excluded from new requirements due to the low-volume threshold, which has been set at less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients.

CMS estimates that over 90% of eligible clinicians will not be subject to a negative payment adjustment in the transition year CMS estimates that over 90% of MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment in the transition year, and that at least 80% of clinicians in small and solo practices with 1-9 clinicians will receive a positive or neutral MIPS payment adjustment.

You can provide your feedback to CMS regarding the final rule for the QPP. The final rule will be open for comment for the next 60 days. Comments can be submitted to CMS through the CMS website.

We’ll keep you updated as we continue to analyze the 2,398-page final rule and what it means for your practice.

  • Clinicians can choose to report under the Merit-based Incentive Payment System (MIPS) for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
  • Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.
  • Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment. Alternatively, if MIPS eligible clinicians choose to not report even one measure or activity, they will receive the full negative 4 percent adjustment.
  • MIPS eligible clinicians can participate in Advanced APMs, and if they receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM, they will qualify for a 5 percent bonus incentive payment in 2019.