CMS Eases Eligibility Threshold Again on MIPS Participation

Ken Terry

June 20, 2017

The Centers for Medicare and Medicaid Services (CMS) intends to further raise the threshold for participation in its Merit-Based Incentive Payment System (MIPS). In its much-anticipated proposed 2018 rule for the Quality Payment Program (QPP), which was released today, CMS proposed to increase the threshold to exclude MIPS-eligible clinicians or groups with $90,000 or less in Part B-allowed Medicare charges or 200 or fewer Part B Medicare beneficiaries.

The threshold applies to the 2018 performance year, in which the scores of MIPS-eligible clinicians will determine their negative or positive payment adjustments in 2020. In the 2017 performance year, which determines payment adjustments in 2019, individual MIPS-eligible clinicians or groups with $30,000 or less in Part B-allowed charges or 100 or fewer beneficiaries are exempted from MIPS.

The 2018 QPP proposal represents CMS' plan to lighten the burden of MIPS on physicians while making it easier for them to join advanced alternative payment models that pay bonuses and exempt them from MIPS.

Among other things, the QPP proposal:

  • Offers practices of 10 or fewer clinicians the option to participate in a "virtual group" that can help small practices with performance reporting

  • Allows clinicians to continue using 2014-edition certified electronic health record technology (CEHRT), while encouraging the use of 2015 edition CEHRT

  • Adds bonus points in the scoring methodology for clinicians who care for complex patients or who use 2015-edition CEHRT exclusively

  • Incorporates MIPS performance improvement in quality scores

  • Incorporates the option to use facility-based scoring for facility-based clinicians

CMS is also proposing more flexibility for clinicians in small practices. Under the QPP proposal, the agency would do the following:

  • Add a new hardship exception for clinicians in small practices under the Advancing Care Information performance category

  • Add bonus points to the final score of clinicians in small practices

  • Continue to award small practices three points for measures in the quality performance category that don't meet data completeness requirements

Virtual Groups

Aside from raising the eligibility threshold, the most significant proposed change in MIPS is the advent of virtual groups. Authorized by the Medicare Access and CHIP Reauthorization Act (MACRA), the virtual groups will be composed of 10 or fewer clinicians, including soloists, who will come together for a single performance year. Group members may be in different locations or belong to different specialties. Virtual groups will report to CMS under a single taxpayer identification number.

In the executive summary of the MACRA final rule, CMS "identified significant barriers regarding the development of a technological infrastructure required for successful implementation [of virtual groups]." Some observers say that it would be difficult for a virtual group to aggregate and standardize data from multiple EHRs.

Many physicians will breathe a sigh of relief when they read that CMS will allow them to use their 2014-edition EHRs for another year. Previously, they were supposed to start using the 2015-edition versions for MIPS reporting by January 1, although CMS previously adopted a 90-day reporting period for Advancing Health Information, the successor to meaningful use.

To date, the only major EHRs that have been certified under 2015-edition rules are Epic and Allscripts. While other developers have promised to upgrade their customers to the new version before year's end, it doesn't appear that many practices will be able to fully implement the new EHRs until well into next year.

Explaining the philosophy behind the proposed changes in QPP, CMS Administrator Seema Verma said in a news release, "We've heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient. That's why we're taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork."

Comments on the proposed rule are due by August 30.

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