The Centers for Medicare & Medicaid Services (CMS) recently released the proposed rule for the Quality Payment Program for 2018. We’ve read the 1,000+ pages, so you don’t have to, and some big changes are coming. However, it is important to note that these changes are provisional until they are included in the final rule which should be out sometime this fall.
The change that should impact the largest number of clinicians is the exclusion or “free pass” for those under the low volume thresholds. The proposed change would raise the exclusions from $30,000 or less in Part B allowed charges to $90,000. The proposed change would also raise the exclusion on the number of Part B beneficiaries from 100 to 200 allowing more providers to be excluded from the program.
The Quality performance category will continue to have the largest proportion of the total MIPS Score. For the 2018 performance year, CMS has proposed that the Quality performance category score stays weighted at 60 percent and that the Cost performance category stays weighted at zero percent. Also, for those clinicians claiming a hardship exemption for the ACI category, those percentage points are added to the quality category, bringing it to 85 percent of the total score.
The 2018 proposed rule provides a new reporting option giving smaller practices the ability to report as a virtual group. The proposed rule defines a virtual group as a combination of solo practitioners or a group with 10 or fewer eligible clinicians joining with at least one other solo practitioner or group for a performance period of at least a year. A written agreement amongst the group participants must be submitted by December 1, 2017, for those wishing to report this way in 2018. This short timeline will make it difficult for new virtual groups to form this year, but if your group is already in the process of partnering with other small groups, it may be possible.
All of these changes can bring on some confusion and stress, but, Qsource and atom Alliance are here to help you as we have thousands of other providers. We are a resource for you. Please contact us if you haven’t already. If you have contacted us, we would be interested in an update on your progress, and we can discuss how these changes will affect your plans for 2018 success.
Don Gettinger is the Quality Data Reporting Manager for Qsource, the Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for the state of Indiana. He has more than 12 years’ experience with the QIO program. Don served as the leader of the Improving Health for Populations and Communities project which assisted physician offices with quality improvement projects using health information technology. He is experienced in assisting with planning, selection, and implementation of electronic health record systems and with improving documentation processes to facilitate capture of clinical quality data. Don possesses expertise in Medicare quality reporting programs and regularly provides technical assistance regarding process changes and improvements to meet reporting program requirements and to improve efficiency and quality of care. He and the QIO team assist health care organizations in successfully qualifying for incentive payments from the new Medicare Quality Payment Program.