CMS Proposed Rule for QPP Year 2

On June 20th, CMS released its proposed rule on Year 2 of the new QPP Program.  While this is not the final rule, this proposed rule indicates that Washington has heard the voices of frustrated physicians loud and clear, and they are making an effort to reduce the regulatory burdens MACRA places on physicians.   They are basically giving us another year to breathe more easily and learn more about MIPS.  The key points for private-practice physicians:

  • MIPS eligible clinicians may use either the 2014 or 2015 Editions CEHRT (certified EHR technology) in 2018.
  • Eligible clinicians whose EHR was decertified by CEHRT will have the ability to receive an exemption retroactive to the performance period, 2017.
  • Eligible clinicians or groups with less than $90,000 in Part B allowed charges or less than 200 Part B beneficiaries during their performance period – or the prior period – are exempt from MIPS participation.
  • “Pick your pace” will continue in 2018. While quality and cost reporting will be required for a 12 month period, Advancing Care Information and Improvement Activities will each have a 90 day minimum performance period.
  • Relative values: Quality 60%, Cost 0%, Improvement Activities 15% and Advancing Care Information 25%. ACI can be reweighted to quality for eligible clinicians who meet certain exclusions.
  • Providers can now participate in MIPS as individuals, groups or virtual groups. Virtual groups would be comprised of solo practitioners and groups of 10 or fewer eligible clinicians.
  • CMS will offer small practices – defined as practices with fewer than 10 physicians – the following:
    • a “significant hardship” exemption to opt out of MIPS ACI starting in 2018
    • an added 5 bonus points to the final score
  • MIPS eligible clinicians may submit measures and activities through multiple submission methods. (In the current year, we must use 1 method per performance category.)
  • CMS will continue to allow simple attestation for the improvement activities.
  • While they seem to acknowledge an issue with topped out measures, the details of how they would address those and what might replace them remains unclear. Ophthalmology has many topped out measures so this will be something that we are watching over the next year.

While practices cannot ignore the quality program regulation, I think most will agree that this Proposed Rule indicates a reduced the administrative burden – at least until the end of 2018.

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