Medicare Quality Payment Program; CMS Issues Requirements for 2018

On November 2, the Centers for Medicare and Medicaid Services (CMS) finalized requirements for physician participation in the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) for the 2018 performance year which begins January 1.

CMS has prepared a summary document that compares 2017 and 2018 QPP policies.
For physicians and other eligible clinicians who choose to participate in the QPP through the MIPS payment pathway, CMS continues participation flexibility, but increases the performance threshold that a MIPS eligible clinician will need to meet to avoid a negative payment adjustment in 2020.  Overall, the 2018 program requirements represent a scaling up of the program in anticipation of more rigorous participation requirements in 2019 as required by law.
Highlights from the Proposed Rule
  • For the 2020 payment year (2018 performance year) CMS has finalized that the Cost Category will represent 10 percent of the total MIPS score.  This represents a major departure from CMS' initial proposal to keep the Cost Category weight at zero. Other categories will be weighted as follows: Quality = 50%, Improvement Activities = 15%, Advancing Care Information = 25%
  • CMS is not proposing modifications to the submission criteria for quality measures.  CMS, however, has raised the data completeness threshold for each quality measure from 50 to 60 percent and has expanded the performance period for the Quality Category to include the entire year. 
  • &‹MIPS eligible clinicians can use electronic health records (EHRs) certified to either the 2014 or 2015 editions for the 2018 performance year to receive credit under the Advancing Care Information Category (ACI). Clinicians who use only EHRs certified to the 2015 edition will receive a one-time ACI bonus of 10 percent.
  • CMS finalized additional flexibilities for clinicians in small practices, including adding bonus points to their final MIPS score and exempting from MIPS those clinicians or groups with $90,000 or less in Part B allowed charges or who care for 200 or fewer Part B-enrolled beneficiaries.
  • For the first time, solo practitioners and eligible clinicians in groups of 10 or fewer eligible clinicians can participate in MIPS as a virtual group. Solo practitioners and small groups may only participate in a virtual group if they exceed the low-volume threshold. The virtual group election process is open until Dec. 31, 2017. A CMS virtual group toolkit is available. 
  • CMS will begin scoring improvement in the Quality and Cost Categories starting with the 2020 payment year (2018 performance year).