THE VALUED VOICE

Quality Payment Program Final Rule Issued November 2

Last week, the Centers for Medicare and Medicaid Services (CMS) released the final rule for year two of the Quality Payment Program (QPP; also known as MACRA). This rule, which is of great importance to WHA members and their covered providers, will go into effect January 1, 2018. In the final rule, CMS heeded many of the comments submitted by WHA and other commenters that continues the incremental, flexible implementation of QPP called for by hospitals, health systems and the employed and contracted physicians with whom they partner to deliver care.

Highlights of the final rule include the following:

• Raised the low volume threshold in 2018 for required participation in the Merit-Based Incentive Program (MIPS) to $90,000 and over in Medicare Part B allowed charges and 200 or more Part B beneficiaries (up from $30,000 in Part B charges and 100 beneficiaries in 2017). CMS anticipates that this increase in the low-volume threshold will exclude 134,000 more clinicians than would have been excluded under the previous low-volume threshold, which means that many more clinicians no longer must demonstrate meaningful use of EHR technology in order to avoid Medicare penalties.
• Adjusted the weights to the 2018 MIPS final score as follows:
  • Cost: 10 percent (increased from 0 percent in 2017)
  • Quality: 50 percent (decreased from 60 percent in 2017)
  • Improvement activities: 15 percent (same as 2017)
  • Advancing care information: 25 percent (same as 2017)
• Changed the method and timing of removing topped-out measures. Topped-out measures are those measures that the whole country is scoring at or very close to the highest possible score (usually 100 percent). They get removed because there is no further opportunity to improve care around that measure. Under the final rule, topped-out measures will be removed and scored on a four-year phasing out timeline. Topped out measures with measure benchmarks that have been topped out for at least two consecutive years will earn up to 7 points.
   
• Added virtual groups as a way to participate in MIPS for 2018. Virtual groups may be made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together virtually to participate in MIPS for a one-year performance period.
   
• Added a complex patient bonus where clinicians can earn up to 5 bonus points for the treatment of complex patients.
   
• Added a small practice bonus, which will add 5 points to any MIPS-eligible clinician or small group who is in a small practice (defined as 15 or fewer eligible clinicians), as long as the MIPS-eligible clinician or group submits data on at least one performance category in an applicable performance period.
   
• Extended the 8 percent revenue-based standard under the Alternative Payment Model (APM) Program for two additional years, through performance year 2020. The revenue-based standard is the risk assumed under the APM which is equal to at least a percentage of estimated Parts A and B revenue of the participating APM entities for the performance period.
   
• Provided an additional year to the phase-in period for the total potential risk for an APM entity under the Medical Home Model standard. The following percentages will apply to the estimated average total Medicare Parts A and B revenues of all providers and suppliers in participating APM entities that will be at risk:
  • 2.5 percent for performance year 2018
  • 3 percent for performance year 2019
  • 4 percent for performance year 2020
  • 5 percent for performance years 2021 and after
• Modified the timeframe on which to consider the Medicare fee-for-service payment amounts and patient counts for certain advanced APMs. For advanced APMs that start or end during the performance period (January 1 - August 31 of each year) threshold scores are calculated using dates that the APM entity was able to participate in an advanced APM, as long as they were able to participate for at least 60 continuous days during the applicable QP performance period.
   
• Added a provision that payers may submit payment arrangements authorized under Medicaid, Medicare Advantage and payment arrangements aligned with a CMS multi-payer model. Payers will also be able to request that CMS make other payer advanced APM determinations before the relevant performance period.

Resources on the QPP are available on the WHA website at www.wha.org/macra.aspx. For additional information on the final rule for year two and other QPP issues, contact Kelly Court, WHA chief quality officer, at kcourt@wha.org, or Laura Rose, WHA vice president, policy development, at lrose@wha.org.