CMS Proposes Changes to Potential Penalties for 2016 PQRS and VBPM

Late on Friday, July 14, 2017, CMS released the Proposed 2018 Medicare Physician Fee Schedule (MPFS).  It will be published in the Federal Register on July 21, 2017.  It contains some provisions of interest to practices who might incur penalties from 2016 reporting for either PQRS or VBPM.  The recent release is important because, although MIPS (the Merit-based Incentive Payment System) is currently in effect for 2017, the reporting your practice did in 2016 affects your 2018 payments.  If you were slated to incur a penalty under either or both of these programs in 2018, this may help alleviate the severity of the penalties.

The 2016 PQRS program policy required providers to report 9 measures across 3 National Quality Strategy domains.  The proposal from CMS retroactively changes this to require success in only 6 PQRS measures.

If you successfully reported fewer than 9 PQRS measures, or had 9 but they fell into fewer than 3 National Quality Strategy (NQS) domains, then you were slated to receive a 2% PQRS penalty and a VBPM penalty of either 2% or 4% (for a total reduction to your 2018 MPFS of either 4% or 6%), depending on your practice size.

PQRS:  This proposal would allow those who fell only slightly short to incur no PQRS penalty.  For example, the below are examples of “falling just short”:

• You reported successfully on only 6-8 PQRS measures
• Reported 9 PQRS measures successfully but had only 1 or 2 NQS domains

VBPM:  This proposal would decrease the size-based of 2% or 4 % penalty on VBPM to the following:

• If you are a group of 10 or more providers, your potential penalty would shrink from 4% to 2%
• If you are a solo provider or in a group of 2 to 9 providers, your 2% potential penalty would go down to 1%

If you need help with anything related to the above or with coding, documentation, or ophthalmic practice management, Corcoran Consulting Group can help.

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