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QPP 2018 – More of the Same, But Maybe Even Better!

July 26, 2017

QPP 2018 – More of the Same, But Maybe Even Better!

It's not too late to avoid a 4% penalty this year!

If you haven't started reporting, you have until December 31, 2017 to avoid a penalty. If you want to earn up to a 4% positive payment adjustment or a portion of the $500,000,000 exceptional performance bonus, you must begin reporting by October 1, 2017.

Contact our Practice Management Specialist, Natalie Cohen, MBA, MHA at ncohen@lammico.com for assistance as you work through the QPP program.  

Proposed Rule for QPP Year 2

The Proposed Rule for the Quality Payment Program (QPP) Year 2 was published by CMS on June 20, 2017 along with a Proposed Rule Fact Sheet. The Rule includes language and recommendations that specifically address the needs of small and rural practices, opportunities for solo practitioners to benefit from group participation, and more exemptions regarding EHR usage. In addition to the Fact Sheet, CMS also prepared a slide deck for practice managers to help educate clinicians and other staff on the proposed updates and changes.

In this issue of LAMMICO Weekly, we highlight some of the elements included in the Proposed Rule.  

Some of the proposals remain the same as in the current rule:

  • Cost category will not factor into MIPS score in 2018
  • Types of eligible clinicians
  • Exceptional performance threshold of 70 points
  • Submission methods

Some rules are proposed to change:

  • Low volume threshold increase to ≤ $90,000 in Part B allowed charges, or ≤ 200 Part B beneficiaries
  • Reduce burden on non-patient facing clinicians in Improvement Activities and Advancing Care Information
  • Performance period change
    • 12-month calendar year for Quality and Cost performance categories
    • 90-days for Advancing Care Information and Improvement Activities

Some new concepts:

  • Creation of virtual groups - solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” with at least one other such solo practitioner or group to participate in MIPS for a performance period of a year
  • Add a significant hardship exemption to Advancing Care Information for small practices
  • Improvement scoring for quality

Providers are encouraged to review the Proposed Rule Fact Sheet and submit comments on the proposed rule by 5 p.m. August 21, 2017 and reference CMS-5522-P on all correspondence. Comments can be submitted:

  • Electronically (follow the "submit a comment" instructions), or
  • Hard copy to the addresses listed on the first page of the Proposed Rule

Specifically, CMS is requesting comments on the following 8 MIPS proposals:

1.    Opt-in provision for low-volume threshold excluded eligible clinicians and facility based providers
2.    Virtual groups: Definition and composition, election, process, agreements, reporting requirements
3.    Quality category:
a.    Increasing the data completeness threshold, and
b.    Process to cap and then eliminate topped out measures
4.    Cost category: Remaining at 0%
5.    Improvement category: Change in future years to the group reporting threshold giving full credit to a group when only 1 clinician in the group performs an activity
6.    Calculation for complex patient bonus: New concept: Apply an adjustment of 1 to 3 bonus points to the final score by adding the average Hierarchical Conditions Category (HCC) risk score to the final score. Generally, this will award between 1 to 3 points to clinicians based on the medical complexity for the patients treated.
7.    Whether or not to have a 5-point bonus for small practices extend to rural areas as well
8.    Performance threshold: Changing from 3 points to 15. Comment on whether it should be 6 or 33 instead.

In general, a Pick-Your-Pace style program is proposed to continue into the second year of the QPP.  Eligible clinicians, as they are defined in the Program, will have the option to submit a minimum amount of data to avoid a penalty; or, those clinicians can choose to participate at higher levels with goals of earning up to a 5% positive payment adjustment (an increase from the 4% in year 1) on all Medicare Part B payments in 2020 and possibly a high performers bonus. Again, as in the transition year (2017), failure to participate will result in an automatic 5% negative adjustment on all Part B services in 2020.

The Final Rule is not expected to be released until the fourth quarter of 2017. LAMMICO will continue monitoring the QPP and CMS websites for notifications and information. Policyholders are encouraged to log into LAMMICO.com as a Member to access Practice Solutions after August 1, 2017 for ongoing regulatory updates, risk management education, and practice management tools to help keep your office safe and compliant in the face of ever-changing rules and regulations.

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