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CMS Releases Final Rule for Year 2 of Quality Payment Program

Jaime Rosenberg
Following the transition year and ahead of the full implementation in year 3, CMS made provisions to the Quality Payment Program to make it easier for clinicians to participate in the program, reduce burden, and to get clincians ready for full implementation. 
CMS announced its final rule for the Quality Payment Program (QPP) on Thursday with comment period for year 2.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established the QPP with the goal of supporting patients and clinicians in making their own decisions about healthcare using data-driven insights, increasingly aligned and meaningful quality measures, and innovative technology. The program puts emphasis on high-value care and patient outcomes while minimizing burden on clinicians. The QPP was first implemented the beginning of 2017 and replaced the sustainable growth rate (SGR) formula.

Under the QPP, eligible clinicians can participate in either Advanced Alternative Payment Models (APMs), or the Merit-based Incentive Payment System (MIPS).

In its second calendar year, QPP will face some minor and major provisions to reduce burden and further facilitate participation as clinicians get ready for full implementation in year 3.

“We realize it can be hard for small practices to participate in the Quality Payment Program, so we’re continuing to offer tailored flexibilities for groups of 15 or fewer clinicians,” said CMS in a statement.

The program will exclude eligible clinicians with less than or equal to $90,000 in Medicare B allowed charges, or less than or equal to 200 Medicare B patients. Final scores of small practices will receive an additional 5 points. Small practices and solo practitioners will have the choice to form or join a Virtual Group to participate with other practices.

The program will also provide 3 points for small practices even if they submit quality measures below data completeness standards. A new hardship exemption will be added for the Advancing Care Information performance category.

Currently, the performance category weights for the MIPS final score are: 60% quality, 0% cost, 15% performance activities, 25% Advancing Care Information. Next year will see a change with quality being weighted at 50% and cost being weighted at 10%.

For the 2018 performance period, Medicare Spending per Beneficiary and total per capita cost measures will be used to calculate Cost Performance category. The performance threshold will be increased from 3 points in the transition year to 15 points in Year 2, and the program will continue the phased approach to public reporting QPP performance information on Physician Care.

The final rule will allow the use of the 2014 edition and/or the 2015-certified electronic health record technology (CEHRT), and will give a bonus for just using the 2015 CEHRT. An additional 5 points will also be added to the final score for treating complex patients.

For physicians and practices affected by hurricanes Irma, Harvey, and Maria, and other natural disasters, the Quality, Advancing Care Information, and Improvement Activities performance categories will automatically be weighted at 0% of the final score.

In regard to APMs, CMS has included several measures to incentivize and reward participation. The final rule will more closely align the standards that apply to Medicare and Other Payer Advanced APMs by establishing a generally applicable revenue-based nominal amount standard for Other Payer Advanced APMs.

Several policies will be implemented in order to make it easier for clinicians to participate in advanced APMs by:
  • Extending the 8% generally applicable revenue based nominal amount standard that allows APMs to qualify as Advanced APM for two additional years.
  • Exempting Round 1 Comprehensive Primary Care Plus participants certain currently participating clinicians from the 50 clinician limit that can earn incentive payments by participating in medical home models.
  • Changing the requirement for Medical Home Models so that the minimum required amount of total financial risk increases more slowly.
  • Making it easier for clinicians to qualify for incentive payments by participating in the Advanced APMs that begin or end in the middle of a year.
CMS also included policies that would further simplify and clarify the program. More detail was provided on how clinicians participating in MIPS APMs will be assessed under the APM scoring standard and on how the All-Payer Combination Option will be implemented.

In the summer’s proposed rule, many people took the provisions as CMS backing off of payment reform and slowing down, said Tim Gronniger, senior vice president of strategy and development at Caravan Health, in an interview with The American Journal of Managed Care®. While the core focus of the program remained intact, it was easy to see the confusion.

This was a much clearer statement, according to Gronniger. The implementing of MACRA seems to be on track. In addition, CMS is gradually getting clinicians ready to be accountable for costs, starting in a limited way, and you see that with the 10% weight of cost.

“They didn’t lower their quality completeness standards, and in important ways maintained standards for quality measures,” said Gronniger. “I think the message to physicians and hospitals is that MACRA is not going away. They need to prepare because there are significant revenue and reputation risks if they don’t.”

 
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