In the proposed rule, CMS announced it would hold off scoring cost until 2019. In the final rule, CMS announced cost will be 10% of a clinician’s performance score during the 2018 performance period. The agency will do so to spare clinicians sticker-shock.
“For the 2020 MIPS payment year, we are finalizing a 10% weight for the cost performance category in the final score in order to ease the transition to a 30% weight for the cost performance category in the 2021 MIPS payment year,” CMS explained in the final rule. Remember, the 30% weight is required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
Another scoring change that clinicians should watch for is the higher data completeness requirement for quality reporting. This year, eligible clinicians had to hit 50% of eligible encounters for all reporting methods except the web interface, formerly known as Group Practice Reporting Option (GPRO), and the Consumer Assessment of Healthcare Providers and Systems (CAHPS). Next year they’ll need to hit 60% to make the grade.
The final rule also included these regulations that may look different than what was proposed:
- Quality scoring stays at 50%. CMS had planned to raise the weight of the quality portion of MIPS to 60%, but it will leave it at 50%. That may be a result of the agency’s decision to inject cost into the mix.
- Multiple reporting methods within a performance category. To give clinicians more flexibility, CMS proposed to let providers report quality activities via different routes. For example, a clinician would have had the option of reporting some quality measures on claims and others through a registry. The same option would have been available for improvement activities. However, the agency isn’t ready yet. “Due to operational reasons and to allow additional time to communicate how this policy intersects with our measure applicability policies, this policy will not be implemented for the 2018 performance period but will be implemented instead for the 2019 performance period of the Quality Payment Program,” CMS explained. The agency did clarify that multiple reporting methods will be an option, not a requirement.
- Facility-based measurement. This option would have allowed clinicians who met the definition of hospital-based to ride on the quality coat tails of a hospital where they perform their services. Providers would have been able to use the hospital’s quality score as their own.
Advanced alternative payment models (APMs) provisions
- Financial risk for advanced APMs holds steady. Practices that qualify for the advanced APM side of QPP must meet a nominal risk standard of 8% during performance year 2018, which confirms the risk standard CMS proposed in June (PBN 7/3/17). CMS announced the 8% nominal standard will apply for performance year 2020 as well.
- Eligibility threshold for Comprehensive Primary Care+ (CPC+) practices gets nixed. CMS will do away with the eligibility cap it had proposed on CPC+ participants, which stated that practices with 50 or more eligible clinicians would not qualify for the risk-sharing and scoring benefits of the medical home model. While the cap will apply to other APMs, including practices taking part in other medical home models, it will not apply to CPC+ participants during the 2018 performance year. Larger practices taking part in a non-CPC+ medical home can expect higher financial risk, despite some taking umbrage with the provider cap. “We appreciate the commenter’s concerns, but we believe that the 50-eligible-clinician limit is a reasonable way to distinguish larger organizations more capable of bearing risk from smaller organizations for which the generally applicable financial risk and nominal amount standards would represent a substantial, genuine barrier to participation in advanced APMs,” states the final rule.
- Medical home participants face lower nominal risk than other APMs. For performance year 2018 and beyond, practices operating a medical home will face less financial risk than other groups that qualify as advanced APMs. In 2018, “the minimum total potential risk for an APM entity under the medical home model is adjusted to … 2.5% of” expected revenue under Parts A and B. That nominal-risk score is on track to rise to 3% in 2019, 4% in 2020 and 5% in 2021.
- Advanced APMs can report as few as 60 days’ worth of data. In a wrinkle to the reporting requirements for advanced APMs, CMS will tally performance scores for APMs that “were able to participate for at least 60 continuous days” during the performance period, which runs from Jan. 1 to Aug. 31, 2018.
- CMS expects more providers to qualify as advanced APMs. “We currently estimate that approximately 185,000 to 250,000 eligible clinicians may become [qualifying APM participants] for payment year 2020 based on advanced APM participation in performance year 2018,” states the final rule.