The long-awaited final rule for the 2018 Quality Payment Program (QPP) was released November 2, outlining requirements for the second year of MACRA. The rule will affect physicians' payment in 2020.
We encourage all providers to read the final rule in detail: The plans don’t shift requirements very far from what was included in the June 2017 proposal, but the changes show that CMS is continuing to adjust the program to make it more comprehensive, and to offer more incentives to providers.
2018 is clearly an in-between year for MACRA. The coming year’s requirements are more flexible than last year’s, with a few concessions designed to continue “easing” providers into MIPS at large.
For example, clinicians are allowed to continue using 2014 Edition Certified Electronic Health Record Technology (CEHRT) to report Advancing Care Information, for example, rather than being required to upgrade to the 2015 Edition. (Though those that use the upgraded technology could be eligible for a 10% bonus score.)
But the 2018 rule also lacks some of the concessions providers were hoping for.
For example, the “performance threshold” of 15 points – which many observers were hoping would be lowered – remains unchanged: As opposed to 2017, physicians can’t simply submit one “Quality or Improvement Activity” measure and be eligible for incentives. To meet the minimum requirements, providers must submit enough measures to get at least 15 total points out of a possible 100.
Reporting is another area where doctors have to step up: CMS quadrupled the reporting period for the quality performance category to a full calendar year, for example, and increased the data completeness requirements to 60 percent for EHR, registry and claims-based submission methods.
Even with the upped ante, there are ways the rule minimizes the regulatory reporting burdens. For one, small practices (those with 15 or fewer physicians) receive enhanced flexibility and assistance compared to larger provider groups.
For example, small practices can earn five additional points to their MIPS final score if they submit data on at least one performance category, and three points for measures in the Quality category that can’t meet data completeness requirements for an entire panel due to size of patient base. (In fact, providers and groups with less than $90,000 in Medicare Part B allowed charges, or that care for less than 200 Medicare Part B patients, can be exempt from from participating in the QPP altogether for 2018.)
For providers of all sizes, CMS will award up to five bonus points if their patient population is deemed particularly complex – based on HCC codes and other patient data.
Regardless, the agency still plans to ramp up to full implementation of the MACRA law in 2019, which will be the third year of the program. Taking the requirements seriously now will help providers protect their revenue as payment reform continues – and working with a trusted medical billing firm can help make reporting, complying, and earning incentives a whole lot easier.
Read full final rule here, then contact us to get started with a smart medical billing service.
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