On June 20, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2018 Medicare Quality Payment Program (QPP) rule, addressing participation requirements for 2018 and future years under the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (Advanced APM) pathways created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Under the proposal, CMS will continue to treat the 2018 performance year as another transition year of QPP and maintain program flexibility.

Based on 2018 performance, clinicians and groups will be eligible to receive up to +/- 5 percent in bonuses or penalties on Medicare Part B services provided in 2020 under MIPS. Qualifying participants in an Advanced APM will be eligible to receive a five percent lump sum bonus.

Highlights of the proposed rule include:

• MIPS Weighting For 2018 Performance Year/2020 Payment Year
• Maintain 60 percent weight for Quality
• Maintain 15 percent weight for Improvement Activities
• Maintain 25 percent weight for Advancing Care Information; clinicians can use 2014 or 2015 certified electronic health record technology (CEHRT), with a bonus for using 2015 CEHRT
• Maintain zero weight for Cost; however, CMS seeks comments on introducing this category at 10 percent. CMS continues to develop and test episode-based measures which will be introduced over time.
• Increasing the low-volume threshold to less than or equal to $90,000 in Medicare Part B allowed charges or less than or equal to 200 Part B patients to allow more small practices to qualify for MIPS exemption.
• Implementation of virtual groups, allowing small groups and solo practitioners under two or more taxpayer identification numbers to participate in MIPS as a single group for both 2018 and 2019. Technical assistance will be made available to these practices.
• Implementation of facility-based measures in MIPS to allow clinicians to be assessed based on their facility’s performance.
• Continued recognition of qualified clinical data registries such as the NCDR PINNACLE Registry and the Diabetes Collaborative Registry as MIPS data reporting options.
• Advanced APM
• Maintenance of the nominal risk and qualifying participant thresholds for the Advanced APM pathway
• Implementation of the ‘All-Payer Combination Option’ for the Advanced APM pathway starting in the 2019 performance year
• CMS seeks comments on broadening the definition of Physician-Focused Payment Models to include Medicaid or Children’s Health Insurance Program beneficiaries.
• Other key items are included in this CMS fact sheet.

The ACC will review this rule in further detail and provide more details about member implications in the coming weeks. The ACC will continue to advocate for a clear, streamlined program that appropriately recognizes clinicians for their efforts to provide Medicare beneficiaries with high-quality care. The College will also solicit feedback from member groups in preparation for submitting written comments.

“Next year (2018) will be another transition year for clinicians adjusting to the Quality Payment Program,” said ACC President Mary Norine Walsh, MD, FACC. “While the ACC will be reviewing the rule in detail, we were encouraged to see that CMS has listened to feedback from the public and recognizes a need to continue supporting clinicians in their transition to a value-based payment environment.”

The policies in this proposed rule impact the 2018 performance year and future years year under QPP. To learn about the current requirements for the 2017 performance year, visit ACC’s MACRA Information Hub.

Keywords: Centers for Medicare and Medicaid Services, U.S., Electronic Health Records, Medicaid, Medicare Access and CHIP Reauthorization Act of 2015, Medicare Part B, Physicians, Registries, United States

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