Proposed QPP Rule Benefits Small Medical Practices

Decision Health, June 21, 2017

Small practices could add points to their total performance scores in the merit-based incentive payment system and may qualify for an exemption from EHR requirements.

More small practices may qualify for exclusions from the Quality Payment Program (QPP), claim hardship exceptions from electronic health record (EHR) requirements, and earn automatic bonus points if the proposed QPP rule released June 20 is finalized.

The Centers for Medicare & Medicad Services has proposed increasing two low-volume thresholds that would grant additional exclusions in 2018:

  1. Practices that bill less than $90,000 in Part B charges.
  2. Practices that see fewer than 200 Medicare patients.

These practices would be exempt from QPP requirements in 2018. Those figures are up from $30,000 in Part B charges and 100 Medicare patients in 2017.

Small practices, defined as having 15 or fewer eligible clinicians, also could add five points to their total performance scores in the merit-based incentive payment system (MIPS) "as long as the eligible clinician or group submits data on at least one performance category in the applicable performance period."

That would get them closer to the proposed 15-point performance threshold.

Eligible providers that don't fit within those categories would have to meet these QPP requirements to avoid a 5% cut, or potentially earn a 5% bonus in 2020, according to the proposed rule.

Quality Reporting / No Changes

Eligible providers would need to report six quality measures for at least 50% of encounters that meets a measure's specifications.

Improvement Activities (IAs) /No Changes

Most providers would need to report four activities. Providers who are in rural areas, geographic health professional shortage areas or meet the definition of non-patient facing must report two activities to receive a full score. CMS also will add more improvement activities that show the use of certified electronic health record technology (CEHRT).

Advancing care information (ACI) / Some Changes

Providers would be able to use the 2014 or 2015 edition CEHRT next year to participate in ACI. That's a reversal from the agency's stated plan in last year's final rule. Providers using 2015 CEHRT would have to report 15 measures while those using 2014 CEHRT would have to report 11. Small practices would be able to take advantage of a hardship exemption that would mean they would not be scored on their ACI performance.

CMS would shift the score for the category to the quality performance category. CMS intends to add exclusions for the e-prescribing and health information exchange measures. It plans to allow clinicians "to not report on the immunization registry reporting measure and potentially earn 5% each for reporting any of the public health and clinical data registry reporting measures as part of the performance score, up to 10%."

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