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CMS thinks small for QPP 2018

More small practices can quality for exclusions from the Quality Payment Program (QPP), claim hardship exceptions from electronic health record (EHR) requirements or earn automatic bonus points if the proposed QPP rule released June 20 is finalized.
CMS proposed increasing two low-volume thresholds that would grant additional exclusions in 2018: Practices that bill less than $90,000 in Part B charges or see fewer than 200 Medicare patients would be exempt from QPP requirements in 2018. Those figures are up from $30,000 in Part B charges and 100 Medicare patients in 2017.
Small practices, defined as 15 or fewer eligible clinicians, also could add five points to their total performance scores in the merit-based incentive payment system (MIPS) “as long as the eligible clinician or group submits data on at least one performance category in the applicable performance period.” That’ll get you closer to the proposed 15-point performance threshold.
However, eligible providers who don’t fit in those categories would have to meet these QPP requirements to avoid a 5% cut – or potentially earn a 5% bonus – in 2020, according to the proposed rule:
  • Quality reporting – no change. Eligible providers will need to report six quality measures for at least 50% of encounters that meets a measure’s specifications.
  • Improvement activities (IAs) – no change. Most providers will need to report four activities. Providers who are in rural areas, geographic health professional shortage areas or meet the definition of non-patient facing must report two activities to receive a full score. CMS also will add more improvement activities that show the use of certified electronic health record technology (CEHRT).
  • Advancing care information (ACI) – some change. Providers will be able to use the 2014 or 2015 edition certified EHR technology (CEHRT) next year to participate in ACI. That’s a reversal from the agency’s stated plan in last year’s final rule. Providers must report a numerator of at least one or a “yes” response for the yes/no measures in five of 15 ACI measures if they're using 2015 CEHRT and four of 11 ACI measures if they're using 2014 CEHRT to earn the 50 percentage points in the base score.
More notable proposed QPP provisions
  • CMS won’t count resource use in 2018 scores. The resource use, aka cost, category that was not scored in 2017 will continue to be unscored in 2018. For the initial MIPS year, the cost category did not count toward the final MIPS score, but CMS planned to make the cost category worth 10% of scoring in 2018. However, this rule proposes to keep it at 0% for the 2018 performance year/2020 payment year “to improve clinician understanding of the measures and continue development of episode-based measures that will be used in this performance category.” To that end, CMS will develop new episode-based measures “with significant clinician input,” the rule says. The quality category is staying at 60% of the score rather than moving down to 50%, as was originally proposed.
If the proposed rule is finalized, the apportionments in 2018 will be 60% for quality, 25% for advancing care information and 15% for clinical practice improvement activities – the same as now.
  • Reporting periods for various MIPS components could vary. Under the proposed rule, you would need to report quality measures for a full year, up from 90 days in 2017. However, the required performance period for ACI and IAs would remain at 90 days, according to the proposed rule.
  • Virtual groups on the horizon for 2018. Be prepared to get virtual in year two of the MIPS program, when CMS is proposing to open up virtual-group reporting. That means small group practices – either solo providers or those with 10 or fewer clinicians – can band together and report the full MIPS slate as a single unit. Virtual groups would need to surpass the proposed low-volume thresholds in order to be eligible for the joint reporting option. CMS notes that interested providers would be required to elect the virtual-group reporting option before the calendar turns to 2018.
  • Risk under advanced alternative payment models (APMs) extended. You’ll find the same 8% required potential risk for APMs through 2020, according to the proposed rule. Already, the risk amount, which is based on total Medicare revenue, was locked in for 2018, but now you’ll find two additional years on the docket at the current rate.
Stay tuned for more coverage of the Quality Payment Program proposed rule.
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