The proposed rule for 2019 was released on July 12, 2018. Meridian Medical Management posted a high overview of proposed changes to Payment Policies under the Medicare Physician Fee Schedule. There are also changes proposed for the Quality Payment Program. Amongst the proposed changes are:
- Changing the definition of MIPS eligible clinicians to include physical therapists, occupational therapists, clinical social workers, and clinical psychologists.
- Having a third element of the low-volume threshold determination by adding the number of covered professional services provided of >200. If an eligible professional meets one or two elements of the low-volume threshold determination, they will be given the choice to participate in MIPS which is now referred to as the “opt-in policy”.
- Adding new episode-based measures to the Cost performance category.
- Restructuring the Promoting Interoperability (formerly ACI) performance category.
- Creating an option to use facility-based Quality and Cost performance measures for certain facility-based clinicians.
- The Quality category being worth 45% of the overall MIPS score, and increasing the cost category to 15%.
- Increasing the payment adjustment of 7% compared to 5% this year.
- Performance threshold may change from 15 points this year to 30 points; that is twice as many points needed to achieve a neutral fee adjustment.
- To be considered a high performer this year you need > 70 points, next year they are proposing > 80 points.
These are just a few of the changes proposed for the Merit-Based Incentive Payment System (MIPS) in year 3 – reporting year 2019. Please access the fact sheet on proposed changes to the Quality Payment Program (QPP) at https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-QPP-proposed-rule-fact-sheet.pdf. To view the CY 2019 Physician Fee Schedule proposed rule, please visit: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf
The comment period for the proposed changes to the Payment Policies under the Medicare Physician Fee Schedule as well as the proposed changes to the QPP will end on September 10, 2018 at 5 pm. This is your time to submit any concerns regarding these proposals. It is the responsibility of every practice to review the changes for both the QPP and proposed changes to Payment Policies under the Medicare Physician Fee Schedule as there are many proposals that may negatively impact your practice. The final rule is usually released in October – November and Meridian Medical Management will notify clients.