On November 2, 2017 CMS issued the final rule for the 2018 Quality Payment Program (also known as MACRA). RBMA submitted comments to CMS on August 21, 2017 in response to their proposed ruled issued in July. Please find attached a summary highlighting the areas RBMA commented on and CMS'response. (Attached Shae's information)
Among the highlights of the final rule:
CMS continues to recognize that eligible clinicians need more experience with this program and is continuing a "pick your pace" participation level while setting the ground work for year 3 which must adhere to the statute.
- CMS increased the threshold for those clinicians who are exempt from participating from $30,000 in Medicare allowed charges or < 100 Medicare patients to $90,000 in Medicare allowed charges (payments) or < 200 Medicare patients.
- There are still two tracks for eligible clinicians to choose from: Medicare Incentive Payment System (MIPS) & Advanced Alternative Payment Models (AAPM)
- Clinicians who participate in MIPS will be scored in four performance categories:
- Quality – 50%
- Cost – 10%
- Improvement Activities – 15%
- Advancing Care Information – 25%
Quality – 50% of Total Composite Score.
- Providers must report at least 6 measures; you may report more than 6 measures, however, CMS will only score your best 6.
- Measures must be reported for 12 months beginning January 1, 2018 (vs. 90 days in 2017).
- Data completeness (the percentage of patients you must report on) threshold is increased to 60% of all payers (vs. 50% in 2017.)
- Measures 21, 23, 224, 262, 352 & 359 are considered "topped out" for 2018 which will yield a maximum of 7 points for meeting performance.
- Possible bonus points are available if you can illustrate performance "improvement" in quality scoring year over year.
Cost – 10% of Total Composite Score
- The Cost category is calculated by CMS based upon clams' submission and there is no reporting requirement for clinicians.
- NOTE: RBMA is encouraging members to review prior year QRUR reports and review patients who have been attributed to their groups. It is recommended you strive to understand the variables that contributed to these patients being attributed to your Tax ID under the PCP and Medicare Spend Per Beneficiary attribution methodologies. Table 5 in the QRUR reports provides the detail of these attributions.
- In 2019 CMS is required statorially to increase the weight of this scoring to 30%.
Improvement Activities – 15% of Total Composite Score
- No change to the number of activities required.
- CMS has added 21 new activities that qualify.
- Clinicians will report activities done within a 90 day period.
- Only one clinician in the Tax ID is required to satisfy the Improvement Activity for the entire TIN to earn 15%.
Advancing Care Information – 25% of Total Composite Score
- No change to 90 day reporting period.
- Non patient facing clinicians are exempt from having to meet this performance category and the percentage is reweighted to quality.
- CMS is including POS 19 (off campus outpatient hospital settings) in the consideration of Non patient facing status.
- CMS will allow use of decertified EHRs to satisfy this performance category.
Other Relevant Details
- Positive/Negative payment adjustment increases to a maximum of 5% (from 4% in 2017)
- Bonus points are available to small practices (defined as 15 or few providers) and small practices are automatically exempt from meeting Advancing Care Information submission requirements.
- Clinicians can earn bonus points for caring for complex patients.
- Groups must use a consistent reporting method for each performance category; however, reporting methods may vary from category to category.
- Providers with 10 or fewer eligible clinicians may form virtual groups to meet MIPS requirements and there is no limit on the number of TINS or the number of specialties within a Virtual Group.
- A MIPS score of 15 avoids a negative payment adjustment; a score of 70+ earns the exceptional performance bonus.
- CMS expanded the type of payment models that qualify for Advanced Alternative Payment Model (A-APM) eligibility. (MSSP Track 1, Next Gen ACO's etc..)
Join your colleagues on January 23 at 1 pm ET for an inside look into MACRA as RBMA's Chapter Consortium presents a webinar:
MIPS In 2018 – The Final Rule Summarized presented by RBMA Past-President Barbara Rubel, MBS, FRBMA; Senior VP, Marketing & Client Services, MSN
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Bob Still, FRBMA
Executive Director, RBMA
Fairfax, VA
bob.still@rbma.org------------------------------