Medicare’s Quality Payment Program Rule for Year 2 (MIPS/MACRA)

The Centers for Medicare and Medicaid Services (CMS) released the final rule for the Quality Payment Program’s second year on November 2, 2017.

Click here for an extensive overview of the rule.

Click here for an executive summary of the rule:

 

Among the highlights:

From 90 Days to a Full Year
Physicians will be required to report quality measures for a full year.  The current standard is a 90-day period.

Cost Counts for MIPS
A physician’s Merit-based Incentive Payment System (MIPS) score is made up of four categories: quality, cost, improvement, and Advancing Care Information (ACI), which takes into account the use of EHRs.

Next year, CMS will count performance on cost measures for 10 percent of a physician’s score, even though CMS indicated earlier that it would delay factoring cost into a physician’s score for 2018.

CMS stated that it will use the Medicare spending beneficiary and total per-capital cost measures to calculate the cost performance category score for the 2018 MIPS performance period. Physicians will not be required to take any action because CMS will calculate the scores. The two measures carry over from the Value Modifier program.

The agency said that is developing new episode-based measures on cost with stakeholder input and soliciting feedback on some of those measures in the fall of 2018. CMS also said that it expects to propose new cost measures in future rules and solicit feedback on episode-based measures before they are included in MIPS.

Certified EHRs
The rule will allow physicians to use 2014 edition and/or 2015-certified HER technology in year two of the ACI performance category. A performance will be given for using only 2015 CEHRT.

Low-volume Threshold Exception
Physicians were excluded in 2017 if the practice had no more than $30,000 in Part B charges or saw no more than 100 beneficiaries in a year. For 2018, physicians will be excluded if they have no more than $90,000 in Part B charges or see no more than 200 beneficiaries.

Small practices that do participate in MIPS will be provided five bonus points.  Solo and small practices will also have the opportunity to form virtual groups.

Alternative Payment Models (APMs)
As we have stated in the past, not too many orthopaedic services qualify for the Advanced APM portion of MACRA.  As a result, most orthopaedic surgeons are focusing on the MIPS portion for MACRA.

CMS has hinted in the past that it would like to create more opportunities for surgeons to participate in an Advanced APM.  As a result, we are expecting CMS to announce new physician-led bundled payment models in the near future.  Hospital-led bundled payments typically do not qualify as Advanced APMs.

There is extensive commentary regarding APMs in the rule.  For example, CMS indicated that it plans to develop a demonstration project to look at how physicians participating in Medicare Advantage alternative pay models can qualify for bonus payments.

Twenty-one New Improvement Activities
CMS stated:

In this final rule with comment period, we are finalizing updates to the Improvement Activities Inventor. Specifically, as discussed in the appendices (Tables F and G) of this final rule with comment period, we are finalizing 21 new improvement activities (some with modification) and changes to 27 previously adopted improvement activities(some with modification and including 1 removal) for the Quality Payment Program Year 2 and future years (2018 MIPS performance period and future years)Improvement Activities Inventory.