Merit-Based Incentive Payment System

The Centers for Medicare & Medicaid Services (CMS) recently issued their Quality Payment Program (QPP) Year 2 proposed rule, with a comment period through August 21, 2017. The Program’s main goals are to:

• Improve health outcomes
• Spend wisely
• Minimize the burden of participation, and
• Be fair and transparent

For QPP Year 2, CMS is continuing to propose flexibilities to make it easy for clinicians to participate and prepare them for full implementation.

QPP Year 2 Proposals: MIPS

• Low-Volume Threshold: Increase the threshold to exclude individual MIPS eligible clinicians/groups with ≤ $90,000 in Part B allowed charges, or ≤ 200 Part B beneficiaries during a low-volume threshold determination period (Year 1 limits were ≤ $30,000 in Part B allowed charges and ≤ 100 Part B beneficiaries).
• Non-Patient Facing: No change in CMS’ definition of non-patient facing clinicians, though CMS is now proposing this same definition for Virtual Groups.
• Submission Mechanisms: Allow individual MIPS eligible clinicians/groups to submit measures and activities through multiple submission mechanisms as applicable, to meet the requirements of the Quality, Improvement Activities and/or Advancing Care Information performance categories. In Year 1, only one submission category per performance category was allowed.
• Virtual Groups: Not available in Year 1, proposal for Year 2 is to add Virtual Groups as a participation option. This would enable solo practitioners and small groups to join together for the purpose of qualifying for a MIPS score.
• Facility-Based Measurement: Not available in Year 1, proposal for Year 2 is to implement an optional, voluntary facility-based scoring mechanism based on the Hospital Value Based Purchasing Program. This option would only be available for facility-based clinicians having at least 75% of their covered professional services supplied in the inpatient hospital setting or emergency department.
• Quality: Quality measures that do not meet data completeness criteria will get 1 point instead of 3 (small practices will continue to get 3). CMS proposed to use a cap of 6 points for a select set of 6 topped out measures (no policies currently established in Year 1).
• Cost: Currently the cost weight is set for 10% in payment year 2020, and 30% in payment year 2021 and beyond. CMS is proposing a 0% cost weight in payment year 2020, and 30% in payment year 2021 and beyond.
• Improvement Scoring for Quality and Cost: Not applicable in Year 1, the proposal would reward improvement in performance in the Quality and Cost categories for MIPS eligible clinicians/groups when compared to the prior performance period.
• Improvement Activities: No change in the weight to final score of this category, or in the number of activities MIPS eligible clinicians have to report, though more activities to choose from are proposed. Reporting of Improvement Activities would remain the same, allowing attestation. Additionally, there would be no change for group participation – that is, only 1 MIPS eligible clinician in a TIN has to perform the Improvement Activity for the TIN to receive credit.
• Advancing Care Information: Allow MIPS eligible clinicians to use either the 2014 or 2015 Edition CEHRT in 2018; grants a bonus for using only 2015 Edition CEHRT. Reweight the ACI performance category to 0% of the final score for ambulatory surgical center based MIPSs eligible clinicians.
• Complex Patients Bonus: Not available in Year 1, the proposal would apply an adjustment of up to 3 bonus points to clinicians based on the medical complexity of the patients they see.
• Small Practice Bonus: Not available in Year 1, the proposal would adjust the final score of any eligible clinician/group in a small practice (15 or fewer clinicians) by adding 5 points to the final score, as long as the eligible clinician/group submits data on at least 1 performance category in the performance period.
• Final Score: Proposed 2018 performance year final score – Quality 60%, Cost 0%, Improvement Activities 15%, Advancing Care Information 25%. Continue to reweight the ACI performance category to the Quality performance category for participants who meet the exclusions.
• Performance Period: Currently set at a 90-day minimum in Year 1 for Quality, Advancing Care Information and Improvement Activities, the proposal for Year 2 and beyond is a 12-month calendar year performance period for both Quality and Cost, and a 90-day minimum performance period for Advancing Care Information and Improvement Activities.