A Closer Look At Highlights From The Proposed 2018 MACRA Rule
Even though we have not yet completed our first year of Merit-based Incentive Payment System/Medicare Access and CHIP Reauthorization Act (MIPS/MACRA) activities, on June 20, 2017, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2018 Medicare Quality Payment Program rule (QPP). This proposed rule will impact the 2018 performance year and future years under QPP.
For 2018, CMS is increasing the low-volume threshold to $90,000 or less in Medicare Part B charges or 200 or fewer Medicare patients annually, allowing more small practices to qualify for the MIPS exemption. The original threshold was $30,000 in Medicare Part B charges or 100 or fewer Medicare patients.
The MIPS weighting for the 2018 performance year/2020 payment year …
• maintains 60 percent weight for Quality
• maintains 15 percent weight for Improvement Activities
• maintains 25 percent weight for Advancing Care Information.
You can use 2014 or 2015 certified electronic health record technology (CEHRT). You get a bonus if you use 2015 CEHRT. Not many EHR vendors have products certified for the 2015 edition that Stage 3 of meaningful use requires, purely from technical and financial constraints. If you can use a 2015 certified edition EHR, CMS is proposing a bonus of 10 percentage points under the Advancing Care Information category for 2018's performance period.
For now, the MIPS weighting for the 2018 performance year/2020 payment maintains zero weight for Cost. However, CMS is seeking comments on introducing this category at 10 percent. You may want to pay attention to cost controls despite MIPS not measuring them next year as cost scoring goes up to 30 percent for the performance period 2019.
There will be continued recognition of qualified clinical data registries such as that recently announced by APMA for its members.
The CMS introduces virtual reporting groups for next year, 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 available to these practices. The proposed rule defines a virtual group as a combination of solo practitioners or a group with 10 or fewer eligible clinicians banding together with at least one other solo practitioner or group for a performance period of a year. The group participants must submit a written agreement to CMS by December 1 prior to the start of the applicable performance period.
Virtual groups are largely seen as a way to entice smaller practices or solo clinicians to take on more risk to advance their move to value-based care. An important thing to remember in regard to virtual groups is that you will be assessed as a group on all MIPS categories. You won’t be able to cherry pick program options.
Physicians could receive MIPS bonus points for complex patients. The CMS has not defined what complex patient means. My best guess is "complex" means those patients with several medical issues that either are not controlled well and/or those with resulting complications such as diabetes or kidney failure.
The CMS proposed that with complex patient bonus points, there could be a one-time consideration for MIPS-eligible clinicians who care for complex patients in 2018’s performance period) (2020 payment year). Clinicians who care for sicker patients don’t want their scores to be impacted for conditions that are out of their control.
Keep a close eye on CMS announcements and the final rule later this year.
