What You Should Know About The 2018 CMS Quality Payment Program

On November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) released the Final Rule for the 2018 Quality Payment Program. I have read through the majority of the Merit-based Incentive Payment System (MIPS) content. Here are some points of interest:

• The threshold to avoid a penalty moves from 3 to 15 MIPS points.

• The 2014 and/or 2015 Certified Electronic Health Record Technology (CEHRT) is allowed but bonus Advancing Care Information (ACI) points are available if one is using only 2015 CEHRT.

• Eligible clinicians or groups with < $90,000 Part B allowed charges or < 200 Part B beneficiaries are excluded in 2018.

• The Cost category will count for 10 percent of the 2018 MIPS score.

• The CMS will calculate the cost category score by Medicare Spending per Beneficiary (MSPB) and total per capita cost measures.

• The CMS will calculate the Cost category “performance.” There is nothing for DPMs to report for that category.

• Clinicians affected by hurricanes Harvey, Irma or Maria who do not submit 2017 MIPS data will not have a negative adjustment in 2019.

• Clinicians affected by hurricanes Harvey, Irma or Maria can file a hardship exception application for Quality, ACI and Clinical Practice Improvement Activities (CPIA) categories for the 2018 performance period.

• The Quality category moves from 60 percent of the MIPS score in 2017 to 50 percent in 2018.

• Clinicians in solo practice or practices of 15 or less are exempt from the ACI category and the 25 percent from ACI moves to the Quality category for those clinicians.

• There is a new option to participate as a virtual group.

The following are the 2018 reporting periods: Cost, 12 months; Quality, 12 months; ACI, 90 days; CPIA, 90 days.

Dr. Lehrman is on the APMA Coding Committee, serves as an expert panelist on Codingline, and is a Fellow of the American Academy of Podiatric Practice Management (AAPPM). Follow him on Twitter @DrLehrman.