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:
- Practices that bill less than $90,000 in Part B charges.
- 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%."
CMS Won't Count Resource Use in 2018 Scores
The resource use, aka cost, category that was not scored in 2017 would continue to be unscored in 2018. For the initial MIPS year, the cost category did not count toward the final MIPS score, but CMS planned to make the cost category worth 10% of scoring in 2018.
However, this rule proposes to keep it at 0% for the 2018 performance year/2020 payment year "to improve clinician understanding of the measures and continue development of episode-based measures that would be used in this performance category."
To that end, CMS would develop new episode-based measures "with significant clinician input," the rule says. The quality category is staying at 60% of the score rather than moving down to 50%, as was originally proposed.
Apportionments Would Not Change
If the proposed rule is finalized, the apportionments in 2018 would remain at current levels: 60% for quality, 25% for advancing care information, and 15% for clinical practice improvement activities:
- Reporting periods for various MIPS components could vary. Under the proposed rule, providers would need to report quality measures for a full year, up from 90 days in 2017. However, the required performance period for ACI and IAs would remain at 90 days, according to the proposed rule.
- Virtual groups are on the horizon for 2018. Be prepared to get virtual in year two of the MIPS program, when CMS is proposing to open up virtual-group reporting. That means small group practices – either solo providers or those with 10 or fewer clinicians – could band together and report the full MIPS slate as a single unit.
Virtual groups would need to surpass the proposed low-volume thresholds in order to be eligible for the joint reporting option. CMS notes that interested providers would be required to elect the virtual-group reporting option before the calendar turns to 2018.
- Risk under advanced alternative payment models (APMs) are extended. Providers would find the same 8% required potential risk for APMs through 2020, according to the proposed rule.
The risk amount, which is based on total Medicare revenue, was already locked in for 2018, but now providers will find two additional years on the docket at the current rate.