The Centers for Medicare & Medicaid Services (CMS) has released a proposed rule that would make changes in the second year of MACRA’s Quality Payment Program (QPP), with the aim to simplify the program, especially for small, independent and rural practices.
The rule, which dropped late in the afternoon on June 20, is 1,058 pages in length and is the first major update to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) under new federal healthcare leaders in the Trump administration. The MACRA final rule was released in October, just a few months before the first reporting year of the QPP—inclusive of two payment paths that eligible Medicare-participating physicians could partake in—MIPS (the Merit-based Incentive Payment System) and the advanced alternative payment models (APM) track—was set to begin in January 2017. This new proposed rule aims to make changes to year two of the Quality Payment Program in 2018.
“We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient,” CMS Administrator Seema Verma said in a statement that accompanied the proposed rule. “That’s why we’re taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork. CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.”
Specifically, there are a few core areas that healthcare stakeholders will be paying most attention to in this rule. For one, there was significant buzz around the second year of the program being a “transition” year for eligible Medicare clinician participants, similar to what CMS officials, under the Obama administration, did for 2017, with the goal of easing doctors into the quality outcomes-based program in 2017 by making the first year a “pick your pace” period. Essentially, as long as Medicare clinicians reported the minimum amount of data to CMS in year one, they would not be dinged with a negative payment adjustment. However, it doesn’t seem like the government will be offering the same flexibilities in 2018.
Editor’s Note: While there was some initial confusion about if 2018 would be another “pick your pace” year, Healthcare Informatics reached out to CMS for official word, to which a spokesperson from the agency said that the second year of the QPP will not be the same as the 2017 transition year, but several flexibilities are being proposed nonetheless as part of a continued effort to ease clinicians in. Indeed, per CMS, “Some prominent proposals for the Quality Payment Program year two include modestly increasing the performance period requirements to include a full year of data for the Quality and Cost performance categories, though we would not use Cost performance scores for your final score determination. We’re also proposing to increase the performance period to 90-days of data for the Improvement Activity and Advancing Care Information performance categories.”
What’s more, according to CMS, “Clinicians that are not ready to participate in the three (of four) categories, with the increase performance period proposals, could still do well in the program overall by focusing on the performance category that is most important to them. We’re proposing to raise the performance threshold (points) for the Quality Payment Program year two to 15 points [up from 3].
Further, stakeholders were wondering how CMS would offer more help for small practices—many of whom fear that they don’t have the resources to be successful under MACRA. In the new rule, proposals from CMS signal that many more clinicians will be exempt from MIPS once again. The rule proposes increasing clinicians’ low-volume threshold from $30,000 or less in Medicare Part B allowed charges or less than 100 Medicare patients to $90,000 in Part B allowed charges or less than 200 Medicare patients. It was estimated in the final rule last fall that some 380,000 clinicians fell into this low-volume threshold bucket; now, many more small practice clinicians who don’t have high volumes of Medicare patients will be exempt from MIPS in 2018 as well.
Given these new developments, CMS is estimating that less than 40 percent of eligible Medicare clinicians will actually be participating in MIPS in 2018. While this might not come as a surprise to many— especially after the government affirmed last month that some 800,000 clinicians will not be participating in MIPS this year— it’s important to note that for various reasons, most Medicare doctors will not have to be involved in MIPS until 2019 at the earliest.
According to a 26-page CMS fact sheet of the proposed rule, “For the second year of the program, CMS wants to keep what’s working and use stakeholder and clinician feedback to improve the policies finalized in the transition year.”