CMS Releases Final Quality Payment Program Rule

Ken Terry

November 02, 2017

The Centers for Medicare and Medicaid Services (CMS) on Thursday released a final rule with comment period for its Quality Payment Program (QPP), along with its 2018 physician fee schedule rule.

The QPP regulation did not diverge much from the proposed rule released last June. The biggest innovation is that in 2018 the cost of care will form 10% of the score of eligible clinicians participating in the QPP's Merit-based Incentive Payment System (MIPS). For 2017, MIPS's "transition year," cost was weighted at 0% of the score.

In 2018, quality performance will constitute 50% of the MIPS score, down from 60% this year. The Advancing Care Information (ACI) category, the successor to meaningful use, will continue to be weighted at 25%, and improvement activities will still be 15% of the score.

The reporting period for ACI and improvement activities will continue to be 90 days. But performance on cost and quality will be measured for the full calendar year in 2018. The performance period for cost is 12 months this year but isn't counted in the score. In contrast, eligible clinicians have a 90-day reporting period for quality this year, so the switch to full-year reporting in 2018 will be fairly major.

"MGMA [Medical Group Management Association] is very disappointed that CMS quadrupled the length of the quality reporting period under MIPS from the current 90 days to 365 days in 2018," said Anders Gilberg, senior vice president of government affairs for MGMA, in a statement. "This fourfold increase to the quality reporting requirements is in stark contrast to the Agency's statements today that the final rule reduces regulatory burdens. CMS is in effect prioritizing quantity over quality and giving physicians less than 60 days to prepare for the 2018 MIPS requirements."

MGMA had also asked CMS not to measure improvement activities until the agency had more time to analyze MIPS performance data and field test its measurement methods. But CMS disregarded that request in the final rule.

Other Changes

The ACI performance category will be reweighted to 0% in 2018 for eligible clinicians based in ambulatory surgery centers and hospitals, and that portion of their MIPS score will be reallocated to quality. Other clinicians who have a significant hardship, including those whose electronic health records (EHRs) have been decertified, will also be exempted from meeting the ACI requirements.

Clinicians who have been adversely affected by Hurricanes Harvey, Irma, and/or Maria will also be considered for an ACI hardship exception. They must apply for the exception by December 31 of this year.

In addition, clinicians impacted by these natural disasters can apply for reweighting of the quality, cost, and improvement activities categories starting with the 2018 performance period. The deadline to apply for this hardship exception is December 31, 2018.

Advanced alternative payment models (APMs) also will see some changes under the final rule. To be qualifying participants in these APMs, eligible clinicians must bear financial risk for at least 8% of their Medicare revenue. Starting in 2019, the same risk standard will be applied to revenue from commercial payers in QPP's Other Payer Advanced APMs. CMS is extending this risk standard by 2 years, through performance year 2020.

Other areas of the QPP final rule carry over the proposal's provisions in most respects. For example, the threshold for excluding MIPS-eligible clinicians or groups remains at $90,000 or less for Part B-allowed Medicare charges or 200 or fewer Part B Medicare beneficiaries. CMS will still launch its virtual group program for small practices next year. And eligible clinicians will still be able to use either 2014-edition or 2015-edition certified EHR technology in QPP next year.

CMS's final QPP rule, while intended to relieve regulatory burdens on providers, "also reflects the agency's efforts to promote innovation in healthcare delivery aimed at lowering prices, increasing competition and strengthening the relationship between patients and their doctors," said a CMS press release.

CMS has yet to release a time period for the comments on this rule.

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