The interim final rule for the second year of Centers for Medicare and Medicaid Services (CMS) Quality Payment Program (QPP) was released on November 2, 2017. This rule will apply to performance and reporting for calendar year 2018 and impact payment in 2020. Below, I have highlighted a few of the key components of the 1,653-page rule with special attention to the Merit-based Incentive Payment System (MIPS).
To briefly review, there are two pathways for participation in the QPP, namely MIPS and the Advanced Alternative Payment Models (A-APMs). For 2018, we still expect that the majority of surgeons eligible to participate in the QPP will do so via the MIPS pathway. That said, and for reasons discussed below, CMS estimates that approximately half of the 1.2 million MIPS-eligible clinicians will be required to submit MIPS data in 2018. In addition, CMS estimates that approximately 200,000 eligible clinicians will participate in the QPP in 2018 via the A-APMs.
1) Quality – For 2018, CMS continues to require reporting on six measures, one of which must be an outcome measure or other high-priority measure. Should surgeons choose to report on more than six measures, CMS will use the six with the highest score for purposes of calculating their score for the Quality component. However, CMS did increase the percentage of patients on which reporting is required, aka the completeness threshold, in 2018 to 60%. Measures submitted that fall below the completeness threshold will receive one point. Small practices will receive three points for measures that fail to meet the completeness threshold. Multiple options remain available for submission of data, i.e., electronic health record (EHR), Medicare claims, a qualified registry or a qualified clinical data registry (QCDR). For 2018, the Quality component will make up 50% of the MIPS final score.
Those familiar with the 2017 version of MIPS will remember that the Cost component was weighted at zero for the first year of the program. CMS discussed, and indeed, initially proposed, to continue weighing cost at zero for 2018. However, because current law requires CMS to weigh cost at 30% beginning with the 2019 performance period, CMS finalized a 10% weight for cost in 2018 with the goal of making the impact of the transition in 2019 less dramatic. CMS will base its calculation of the cost component on the total per capita costs for all beneficiaries attributed to a provider and the Medicare Spending per Beneficiary measure for the entirety of the 2018 performance period. CMS intends to provide performance feedback on both measures by July 1, 2018. Surgeons are not required to submit data for purposes of cost component.
Advancing Care Information (ACI)
There are no major changes to the scoring policy for 2018 and all the applicable Base Score measures must still be reported in order to receive a score for the ACI component. The performance period requirement remains a minimum of 90 continuous days. For 2018, both 2014 Edition and 2015 Edition certified electronic health record technology (CEHRT) remain acceptable. However, those using only a 2015 Edition will be eligible for a 10% bonus. Regardless of edition used , bonus points are also available for reporting to a public health agency or clinical data registry and for the completion of an Improvement Activity (IA) using CEHRT. A significant hardship exemption remains available for those in small practices. As was the case in 2017, the ACI component represents 25% of the final score. However, as was also the case in 2017, one is not required to have an electronic health record to avoid a penalty in 2018.
The weight assigned to the IA component remains at 15%. CMS added 21 new IAs in the final rule, bringing the number of IA available from which to choose up to well over 110. CMS also made changes to 27 activities previously adopted. Reporting remains a simple attestation of participation in the activity for 90 continuous days. To receive full credit for the IA component, most surgeons will be required to attest to having participated in two, three, or four activities depending on whether the activities chosen are of medium value or high value. This is not a change. However, those in small or rural practices must only participate in one or two activities to receive full credit. It should be noted that for 2018, one will be able to avoid a penalty in 2020 solely by fulfillment of the requirements imposed by the Improvement Activities component.
As mentioned above, CMS estimates that only approximately 622,000 providers out of the 1.2 million eligible will be required to submit data under MIPS. Many providers are excluded from MIPS based on the low-volume threshold. For 2018, CMS set this threshold at less than or equal to $90,000 in Medicare Part B charges OR less than or equal to 200 Medicare Part B beneficiaries. The effect of this change, compared to the values set for 2017 low-volume threshold, is to exclude more providers from MIPS reporting.
Lastly, many will remember that for 2017, the performance threshold was set at three points, and thus, required only minimal reporting in either quality, ACI, or IA to avoid a penalty. It was expected that the threshold necessary to avoid a penalty for 2018 performance would be increased and indeed, CMS has set that value at 15. Those scoring above 15 will be eligible for a positive update in their Medicare payments in 2020, while those scoring below 15 will receive a penalty. Those who choose to not participate in 2018 will receive a 5% penalty in 2020. However, two points made above warrant reiteration:
a) By fully participating in the IA component, one can accrue the 15 points necessary to avoid a penalty.
b) An EHR is not required to avoid a penalty.
In the coming weeks, we will be updating the QPP website (www.facs.org/qpp) to reflect the changes in the program for 2018. New videos will be available as will be new electronic and print materials to assist Fellows to participate in the program.
Dr. Bailey is a pediatric surgeon and Medical Director, Advocacy, for the Division of Advocacy and Health Policy in the ACS offices in Washington, DC.