Proposed Changes to 2018 MIPS and APM Program from CMS
It’s the middle of summer and everyone is on vacation when CMS decided to release their 2018 QPP Proposed Rule featuring MIPS and APM changes. So, enjoy your summer and know that TempDev is exhaustively reading through the release and attending CMS webinars to give you a synopsis of what is going on. The goal of the updated proposal is to reduce clinician burden and make MACRA participation easier. It includes many modifications and prepares clinicians to fully participate in the program. CMS has proposed to treat the 2018 performance year as another transition year of the QPP program.
MIPS program proposed changes:
- Quality and Cost – Increase the performance period to an entire year.
- Improvement Activities and Advancing Care Information(ACI) – Increase the performance period to 90 days’ worth of data, instead of submitting some data to avoid a negative adjustment.
- Composite Scoring – You must receive at least 15 points instead of 3 points to avoid a negative adjustment.
- Virtual Groups – Clinicians will be able to virtually work together to participate as a group.
- Exclusions – Increase the low-volume exclusion threshold to less than, or equal to, $90,000 in Medicare Part B charges or less than, or equal to, 200 Part B patients for eligible clinicians. Currently, the threshold is $30,000 or 100 patients.
- CEHRT Editions – Continue to allow use of 2014 CEHRT (NextGen 5.8/KBM 8.3), however, encourage use of 2015 CEHRT (NextGen Regulatory Release 5.9/KBM 8.4) by building in bonus points for being upgraded.
- Performance Scoring Bonuses:
- Complex Patients – Applies an adjustment of up to 3 bonus points by adding the average Hierarchical Conditions Category (HCC) risk score to the final score.
- CEHRT Editions – A 10-point ACI bonus for using 2015 CEHRT (NextGen Regulatory Release 5.9/KBM 8.4).
- Hardship exemptions and bonuses for small practices – Groups of 15 or fewer clinicians can receive 5 points added to the final score if the eligible clinician or group submits data on at least one performance category in an applicable performance period.
- Facility – Implement facility-based measures to allow clinicians to be assessed based on their facility’s performance
APM program proposed changes:
- Revenue-based nominal standard – Extend through 2020
- Medical home models – Nominal amount standard increases more slowly
- All Payer Combination – More details released for APMs who qualify in the All Payer Combination option.
- APM MIPS – Quality will be weighted at 50%, Improvement Activities at 20%, ACI at 30%, and Cost at 0%.
What does this mean for me?
If you’re an eligible MIPS or APM MIPS clinician, then you are no longer required to upgrade to NextGen 5.9/KBM 8.4 by the end of 2018. However, if your practice can upgrade if at all possible, it is highly recommended as you will receive bonus points, new content, and new features for a more efficient workflow.
If you are participating in an Advanced APM, nothing has changed. You should still upgrade to NextGen 5.9/KBM 8.4 by the end of 2017.
We recommend continuing to review your Quality Measures frequently in NextGen HQM. With the proposal to increase the threshold to 60% and a longer performance period, you should review workflows to ensure you are meeting the measures. Your partners at TempDev can assist you with this.
Comments are being accepted by CMS through August 21, 2017. CMS will then release the final rule thereafter. The fact sheet, executive summary, and the webinars provide a wealth of information regarding the proposal.