2018 Proposed Rules for MIPS

The 2018 proposed rule for the quality payment program (QPP) is scheduled to be published on 06/30/2017. This new program went into effect 1/1/2017 known as the transition year.  The goals of the program are to improve health outcomes of Medicare beneficiaries, spend more wisely, minimize the burden to participate and become more transparent.

Below is a summary of the 2018 proposed rule related to the 4 categories included under the Merit-Based Incentive Payment System (MIPS):

  • Small Practice Bonus (Small Practice is classified as 15 or fewer clinicians)
    • Award 5 points to the final MIPS only if data is submitted on at least 1 performance category within the performance period
  • Offering the Virtual Group Participation option for small groups
    • Groups composed of solo practitioners and groups of 10 or fewer eligible clinicians can collectively become a “virtual” group. The virtual group would report as a group across all 4 performance categories.
  • Increasing the low-volume threshold to allow additional small practices exemption status from MIPS participation
    • Increase the threshold to exclude individual MIPS eligible clinicians with < $90,000 Part B allowed charges or < 200 Part B beneficiaries
  • Continuing the use of 2014 Certified Electronic Health Record Technology (CEHRT)
  • Adding additional measures and activities; notably an improvement activity for Appropriate Use Criteria (AUC). Physicians ordering advanced diagnostic imaging will access an evidence-based AUC to make the most appropriate treatment decisions for specific conditions. Ordering physicians would attest to using AUC through a clinical decision support mechanism
  • Adding bonus points in scoring for those clinicians caring for very complex patients
    • Add up to 3 bonus points to the final MIPS score
  • Allowing for MIPS performance improvement in scoring quality performance and cost
    • Quality improvement will be based on rate of improvement; higher improvement = higher points
    • Cost improvement will be based on statistically significant changes
  • Submission Mechanisms – allowing MIPS eligible clinicians to submit measures and activities through multiple submission mechanisms within a performance category
  • Scoring:
    • Quality – remain at 60% in payment year 2020 (reporting year 2018) and then 30% in payment year 2021 (reporting year 2019)
    • Cost – remain at 0% in payment year 2020 (reporting year 2018) but CMS is currently soliciting feedback to keep it at 10% and then 30% in payment year 2021 (reporting year 2019) and beyond
    • Improvement Activities – no change will remain at 15%
    • Advancing Care Information – no change will remain at 25%; allow continued use of the 2014 edition CEHRT but will grant bonus points for use of 2015 edition CEHRT
  • Potential Payment adjustments
    • -5% – +5% (continuing to achieve budget neutrality)
  • Performance Period
    • Quality and Cost – 12 month calendar year performance period
    • ACI and Improvement Activities – 90 days minimum performance period

We urge you to review the proposed changes and to submit your concerns to CMS during the comment period which ends August 21, 2017. 

For additional information go to https://qpp.cms.gov or  https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-Feedback.html