MIPS Update

August 2017 - Vol. 36, No. 7

On June 20, 2017, the Centers for Medicare & Medicaid Services (CMS) released the 2018 proposed rule for the second year of the Quality Payment Program (QPP). The QPP has two tracks for participation: Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM). In the 2018 proposed rule, CMS proposes several changes to key QPP components, including increasing the low-volume threshold, proposed performance categories reporting requirements, creating virtual groups for reporting, and APM participation requirements. The Academy has published a summary of the 2018 MIPS and APM reporting requirements for otolaryngologists, including details on proposed provisions directly affecting your practices at http://www.entnet.org/content/physician-payment-reform.

Participation

CMS proposes modifying the low-volume threshold, reducing the number of ECs required to participate in MIPS. Under the proposed rule, the threshold for exclusion was increased to ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries, during a determination period. An EC must participate in MIPS if both low-volume thresholds are met or exceeded.

CMS also proposes adding virtual groups as a method for participation in MIPS. Individual ECs and groups of 10 or fewer ECs will be able to form virtual groups with at least one other EC, regardless of location or specialty, to report MIPS performance categories. Virtual groups with 15 or fewer members will have small group status, and virtual groups are eligible for rural and health professional shortage areas (HPSA) designations.

Reporting MIPS performance categories

For 2018, CMS proposes eliminating the “pick your pace” reporting option and implementing a calendar year performance period. The quality and cost performance categories will have 12-month performance periods, and the ACI and improvement activities (IA) performance categories must be reported for a minimum of 90 days for 2018.

ECs can report performance categories using claims, qualified clinical data registries (QCDR), a qualified registry, attestation, or an electronic health record (EHR), depending on the specific performance category. CMS also proposes allowing ECs and groups to submit data on measures and activities via multiple data submission mechanisms for a single performance category.

For 2018, CMS proposes providing ECs or groups defined as small practices with an additional 5 bonus points to the final MIPS score, as long as they submit data on at least one performance category. CMS proposes continuing to award small practices 3 points for measures in the quality performance category that do not meet data completeness requirements. CMS also proposes adding a new hardship exemption for clinicians in small practices under the advancing care information (ACI) performance category.

Performance categories

For 2018, CMS proposes keeping many of the same performance category requirements, including category weights and reporting requirements. Below are the 2017 category requirements compared to the 2018 proposed requirements.