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On Thursday, Nov. 2, 2017, the Centers for Medicare & Medicaid Services released the 2018 final rule for the second year of the Medicare Access & CHIP Reauthorization Act (MACRA) Quality Payment Program (QPP). While we were disappointed by some policies in the 2018 rule, in general, the final rule signals a continued commitment to increased flexibility and reduced administrative burden for clinicians.
Starting in 2019, Medicare-participating clinicians will have to choose whether they will participate in the new QPP through one of two tracks: the fee-for-service based Merit-Based Incentive Payment System (MIPS) or through an Advanced Alternative Payment Model (APM). Clinicians should be reporting measures now (in 2017) for payment adjustments that will occur in 2019. If you are not aware of your obligations under the QPP, be sure to familiarize yourself as soon as possible – most clinicians should be reporting on three MIPS categories (quality measures, advancing care information, and clinical practice improvement activities) now for changes that are coming in 2019.
The final rule that outlines the QPP program in 2018 significantly reduces the number of providers subject to scoring under the MIPS track of the QPP. In 2018, any clinician with less than $90,000 in Medicare Part B allowed charges or fewer than 200 Part B beneficiaries will be exempt from MIPS reporting (previously this “low-volume threshold” was $30,000 in Part B charges and 100 Part B patients). With these changes, it is estimated that 123,000 providers will be excluded from MIPS scoring. CMS is also expanding access to reporting under the Advanced Alternative Payment Model (APM) track of the QPP. Clinicians who are participating in the Medicare Shared Savings Program (MSSP) Track 1+ as well as the Next Generation ACO Model and the Comprehensive Primary Care Plus (CPC+) program will all now qualify for QPP reporting as an advanced APM. CMS estimates that about 185,000 to 250,000 clinicians will now be eligible for reporting under an advanced APM, creating more competition within the MIPS track. CMS also expanded the option of reporting as virtual groups for physicians in groups of 10 or fewer and added bonus opportunities for small practices and clinicians treating complex patients.
CMS also eases reporting requirements around electronic health record (EHR) use, allowing MIPS-eligible physicians to be able to use 2014 or 2015 editions of certified EHR technology to meet the Advancing Care Information (ACI) category. Additionally, clinicians across the U.S. who were significantly affected by Hurricanes Harvey, Irma, and/or Maria are eligible to apply for an ACI hardship exception. These affected clinicians are eligible to apply for reweighting of the MIPS reporting requirements for quality, cost, and improvement activities categories for the 2018 performance period. The deadline to apply for both exemptions is December 31, 2017.
Despite these flexibilities, ACCC is disappointed to see that CMS has moved up the timeline to hold clinicians accountable for the cost of care they provide. Originally CMS had proposed that the cost category under MIPS be weighted at zero in 2018, however the final rule requires that cost account for 10% of the MIPS score in 2018. Additionally, despite opposition from ACCC and many stakeholders, CMS also finalized that Part B drug revenue will be subject to the MIPS adjustment, which is not what we believe Congress intended and breaks from past precedent in CMS policies.
We expect QPP participation and requirements will continue to evolve in the coming years, but be sure to prepare yourself now – these changes to Medicare reimbursement are around the corner.
ACCC members are invited to join us for a webinar on Wednesday, December 6, 2017, from 3-4 PM EST, for an in-depth analysis of the CY 2018 QPP final rule and how these changes may impact providers and their cancer program or practice. Learn more and register (log in required).