In the continued march toward value-based care along with furthering its pledge to “put patients over paperwork”, CMS recently announced proposed changes to the Quality Payment Program (QPP) for the 2019 reporting period. CMS hopes that the proposed changes will continue to help ease the administrative burden attributed to physician burnout in meeting federal reporting requirements.
Payment Adjustments Continue to Rise and Eligibility Expands
Payment adjustments for eligible clinicians for the 2019 reporting period will continue to rise steeply at up to +/-7% for 2021 payments. According to CMS, this means that there will be approximately $372 million available for incentive payments based on expected MIPS participation for the 2019 reporting period.
The 2019 proposed changes include expanding on existing eligibility to include additional clinician types as well as adding in a third element to the low-volume threshold for determining MIPS eligibility:
Sourced from 2019 QPP Proposed Rule for the Quality Payment Program: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-QPP-proposed-rule-fact-sheet.pdf
Opt-In Policy for Exempt Clinicians
MIPS Eligible Clinicians who meet or exceed one or two, but not all, components of the Year 3 (2019) proposed low-volume threshold criteria, would be able to opt-in and participate in MIPS via the following scenarios:
Performance Category Highlights
There are no proposed changes to the 2019 performance period, meaning reporting requirements would remain the same as in 2018 for each MIPS category:
Additionally, the same data completeness requirements would be in place as in 2018. For claims submissions, this would be 60% of Medicare Part B patients for the full reporting period. For QCDR, qualified registry, and EHR submissions, this would be 60% of the eligible clinician’s or group’s patients across all payers for the performance period.
As part of the CMS move toward streamlining requirements and prioritizing outcome measures over process measures, CMS has proposed to remove MIPS 426 (Transfer of Care to PACU) and MIPS 427 (Transfer of Care to Intensive Care Unit) from the MIPS Quality component.
Other scoring changes would be as follows:
Small Practices See Continued Flexibilities
With the proposed changes, small practices would continue to see flexibilities in MIPS reporting requirements, including retaining the small practice bonus for participation and a potential earning of three points for quality measures that do not meet data completeness requirements. CMS also proposed to consolidate the low-volume threshold determination periods to better identify groups with the small practice designation.
Other Key Changes Include:
· Streamlining the MIPS determination period for different categories of clinicians to more clearly capture the low-volume threshold and special status designations: non-patient facing, small practice, hospital-based, and ASC-based.
· Raising the performance threshold from 15 points in 2018 to 30 points for 2019 reporting. And increasing the additional performance threshold from 70 points in 2018 to 80 points for 2019 reporting.
· Creating an option to use facility-based Quality and Cost performance measures for certain facility-based clinicians.
All proposals are still subject to change until finalized by CMS. Stakeholders can comment on the proposed changes to the Quality Payment Program until September 10, 2018.