For most people, summertime means backyard barbecues, ball games, and vacations. But for those of us in health IT, it also means reviewing the proposed 2018 Quality Payment Program Year 2 changes under MACRA. The proposed ruling was released on June 20th, and coming in at 1,058 pages it makes for a seriously long beach read.
In its opening statement, CMS lists the program’s main goals as:
- Improve health outcomes
- Spend wisely
- Minimize burden of participation
- Be fair and transparent.
While there are tons of changes in here, minimizing the burden and being fair and transparent stuck with me as I reviewed them. With the Final Ruling fast approaching, organizations are looking at a tight timeline for these regulations. The MIPS track impacts the greatest number of eligible clinicians, and it is where the bulk of the changes reside. Here’s how the new administration aims to meet these goals for them:1. Raise the low volume threshold for MIPS eligible clinicians to greater than or equal to $90,000 or greater than or equal to 200 enrolled beneficiaries.
This would potentially exclude an estimated 135,000 additional clinicians from MIPS reporting. This same threshold applies to practices or health care organizations that report as a group, so a number of these physicians will still be required to report.2. Weight Cost at 0% for a second year.
By law, cost must be weighted at 30% in the 2019 reporting year. CMS solicited comments at keeping cost at the original 10% weighting for the next submission year to allow for a lead in. Since cost is calculated from claims data, results will continue to be included in MIPS feedback reports.3. Facility-based measurement for hospital-based clinicians.
Hospital-based clinicians could elect to use their attributed hospital’s Value-Based Purchasing (VPB) score to calculate MIPS Quality and Cost components via a conversion algorithm. CMS has stated that this assesses hospital-based clinicians in the context of their facilities which is a better measure of their quality, as well as helps reduce the burden of reporting.4. Reduced improvement activity requirements for non-patient facing clinicians.
Clinicians that meet the criteria for being non-patient facing can report 2 medium or 1 high level activity for full points in this category.5. Allow the continued use of 2014 CEHRT technology in 2014 for Advancing Care Information.
This change is similar to the recent one finalized for the Inpatient Prospective Payment System (IPPS). Bonus points would be provided for the use of 2015 CEHRT technology in 2018. Additionally, there is a proposed hardship exemption for small practices to reweight ACI to 0% and reallocate the 25% to quality.6. Virtual Groups.
Originally proposed for 2017, Virtual Groups are more than one group with 10 or fewer clinicians that report together and are scored collectively as a group. CMS is proposing no limit on the number of groups that a Virtual Group can be comprised of, and no limits on geographic areas or specialties. While originally intended to increase flexibility and ease reporting for small groups, the jury is still out on this concept. Only 16 Virtual Groups are forecasted for 2018. Challenges are data aggregation for reporting and choosing practices to partner with that will enhance performance scores rather than detract from them. CMS has said that it will define a “Model Agreement” and provide a template for practices seeking to enter this partnership.7. Increased but continued reduced reporting and scoring requirements.
While the proposal raises the minimum score from 3 to 15, this is still easy to obtain. Additionally, several vehicles for bonus points have been proposed. Reporting requirements remain at 90 days for Advancing Care Information and Improvement activities, while Quality is proposed at a full 12 month submission.
However, the biggest burden of participation and hurdle to fairness and transparency remains - the incredibly aggressive timelines. Final comments on the proposed Quality Payment Program Year 2 changes were submitted as of August 21. The Final Ruling is expected November 1, 2017 with an effective date of January 1, 2018. This gives everyone only 60 days to prepare before the changes come into effect. So this holiday season, I’ll be replacing my copy of the proposed regulation with its spots of barbecue sauce and sunscreen on it for the final regulation, which I'm sure will end up dotted with gravy and cranberry sauce.
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