The day after the federal Centers for Medicare and Medicaid Services (CMS) released the final rule making changes in the second year of the Quality Payment Program (QPP) under the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) law, healthcare industry leaders are voicing mixed reactions, but do seem satisfied with some of the increased flexibilities that were maintained from the proposed rule, and intended to provide clinicians with a smoother transition to the Quality Payment Program.
Late in the afternoon on Thursday, Nov. 2, CMS published the 1,653-page calendar-year 2018 QPP final rule, under the MACRA law, affecting Medicare-participating physicians covered either under the MIPS (Merit-based Incentive Payment System) program, or participating in APMs (advanced payment models). It’s clear that easing provider burden in complying with MACRA was a priority for CMS officials in keeping with many of the proposals in the proposed rule.
In a press release announcing the final rule, CMS officials stated, “While part of CMS’s broader strategy to relieve regulatory burdens for providers, these rules also reflect the agency’s efforts to promote innovation in healthcare delivery aimed at lowering prices, increasing competition and strengthening the relationship between patients and their doctors.”
“During my visits with clinicians across the country, I’ve heard many concerns about the impact burdensome regulations have on their ability to care for patients,” Seema Verma, CMS Administrator said in a statement. “These rules move the agency in a new direction and begin to ease that burden by strengthening the patient-doctor relationship, empowering patients to realize the value of their care over volume of tests, and encouraging innovation and competition within the American healthcare system.”
Some of the key changes in the final rule include raising the MIPS performance threshold to 15 points in year 2, from 3 points in the transition year, and the final rule allows the use of 2014 edition and/or 2015-certified electronic health record technology (CEHRT) in year 2 for the Advancing Care Information performance category, and gives a bonus for using only 2015 CEHRT. For the 2018 MIPS performance year final score, the performance category weights will be: quality, 50 percent; cost, 10 percent; improvement activities, 15 percent; and Advancing Care Information, 25 percent. A 26-page fact sheet summarizing the final rule can be found here.
Some healthcare industry leaders have expressed concerns about CMS’s decision to require a full-year reporting period for the cost and quality performance category, rather than a 90-day reporting period.
Anders Gilberg, senior vice president of government affairs at the Medical Group Management Association (MGMA), said in a statement, “MGMA is very disappointed that CMS quadrupled the length of the quality reporting period under MIPS from the current 90 days to 365 days in 2018. This fourfold increase to the quality reporting requirements is in stark contrast to the Agency’s statements today that the final rule reduces regulatory burdens. CMS is in effect prioritizing quantity over quality and giving physicians less than 60 days to prepare for the 2018 MIPS requirements.”
It should be noted that the final rule sets a 90-day reporting period in both 2018 and 2019 for Advancing Care Information and Improvement Activities performance categories.
According to CMS, the final rule includes a number of policies designed to provide clinicians with a smoother transition to the Quality Payment Program. “The QPP final rule includes policies that reduce burden and support clinicians in small and rural practices to successfully participate in this program. CMS is decreasing the number of clinicians required to participate,” CMS stated in the press release.
“There weren’t a whole lot of surprises” with the final rule,” notes Jeff Smith, vice president of public policy at the American Medical Informatics Association (AMIA). “When you focus on the quality payment program in MIPS, I think CMS telegraphed that they want to provide much more flexibility and are looking for ways to make the program more feasible for docs, and I think the final rule really does follow through with that intention.”
Adaeze Enekwechi, Ph.D., vice president of McDermott + Consulting, a Washington, D.C.-based healthcare consulting firm, who previously worked at the White House Office of Management and Budget (OMB) under the Obama Administration as the associate director for health programs, contends that CMS designed year 2 of the MACRA QPP as a gradual ramp up to full implementation in 2020.