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March 27, 2018

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QPP Final Rule Aims to Ease Full Transition to the Payment Program

December 7, 2017:

In mid-November, the Centers for Medicare and Medicaid Services published a final rule with comment period for what they are referring to as Year 2 of the Quality Payment Program. The rule makes many revisions to the program in response to feedback from the first, transition year. In general, the changes center on lightening the administrative burden on providers, encouraging providers to participate, and readying clinicians for full participation in the program.

Under the QPP, eligible providers are paid based on the quality of care they provide through either the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs). The transition year for QPP was 2017, during which clinicians could choose not to participate at all, or to partially or fully participate. In 2018, CMS is encouraging more participation to foster gradual transition to full implementation of the program, set for performance year 2019. Data submitted during 2019 will affect payment in 2021.

In the November 2017 final rule, CMS is adjusting the points awarded under MIPS for those with special circumstances, such as providers who treat complex patients or those in small practices. It is also increasing the low-volume threshold in 2018 to $90,000 or less in Medicare Part B payments or 200 Part B patients. Anyone below this threshold is exempted from participation in the program. In addition, recognizing the devastating effects of several hurricanes in 2017, Medicare will not give any weight to the performance category “Quality, Advancing Care Information, and Improvement Activities” for 2017 for those affected by these weather events. CMS is also awarding bonus points and offering participation options for small practices. For example, the agency will add 5 bonus points to the final scores of such practices and is continuing to grant 3 points for measures in the Quality performance category that are incomplete. Another key change is that the Cost performance category will be weighted at 10 percent for 2018, impacting the 2020 payment year; in 2017 this category was weighted at zero and the additional 10 percent was reassigned to the Quality performance category; this category will now be weighted at 50 percent. In the Improvement Activities performance categories, CMS has finalized more activities, up to approximately 112 from 92 in 2017. No major changes are implemented in the Advancing Care Information category, though a 10 percent bonus is being offered to eligible clinicians (ECs) using the 2015 edition of CEHRT only.

In another example of providing more flexibility and incentives for participation, small group practices of 10 or fewer clinicians will be able to join a “virtual group” in 2018; this means ECs can participate in MIPS as a group with other small practices. CMS defines a virtual group as two or more tax identification numbers (TINs) assigned to one or more solo practitioners or groups with 10 or fewer eligible clinicians that join together for a performance period for one year. To be eligible for such a group, the solo eligible clinician or group must exceed the 2018 low-volume threshold. Once the group is formed, it must meet the requirements for each performance category and must collect and aggregate data from all group participants. The deadline for electing to participate in a virtual group is December 31, 2017. For more information and access to the CMS-developed “Virtual Groups Toolkit,” visit: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html.

For APMs, CMS is adding incentives for clinician participation in payment models offered by Medicare and, starting in 2019, by payers other than Medicare. For example, CMS is easing the qualifications for receiving incentive payments for clinicians participating in Advanced APMs that begin or end in the middle of the year. It also adds some flexibility and ways providers can be successful participating in the All Payer Combination payment option that begins in performance year 2019. CMS has also opted to continue the generally applicable revenue-based nominal amount standard of 8 percent for an additional two years; this is the standard an APM must meet to qualify as an Advanced APM. CMS has offered clarifying details regarding how ECs participating in select APMs known as MIPS APMs will be evaluated under the APM scoring standard. Lastly, more flexibilities and pathways were discussed in relation to the implementation of the All-Payer Combination option; this is a means by which a clinician can become a qualifying APM participant (QP) by participating in a combination of Advanced APMs and Other Payer Advanced APMs and will be available beginning in 2019.

CMS has published a comprehensive table comparing MIPS and APM policies for performance year 2017 with those for performance year 2018. It can be accessed at:



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