CMS has proposed new regulations to continue implementing the “Quality Payment Program” (QPP) — the new Medicare physician fee schedule (MPFS) update framework mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). As previously reported, starting in 2017, physicians will be paid under the Merit-based Incentive Payment System (MIPS) or the Advanced Alternative Payment Model (APM).
For the second year of the QPP, CMS is proposing to continue a number of transition policies established for 2017 while “ramping up to full implementation.” Notably, with regard to the MIPS track, CMS proposes to:
- Establish a Virtual Groups participation option. Virtual groups would be comprised of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” with at least 1 other such solo practitioner/group to participate in MIPS for a one year performance period.
- Increase the low-volume threshold to exempt more small practices and clinicians in rural and Health Professional Shortage Areas.
- Add bonus points under the scoring methodology to account for (1) caring for complex patients, and (2) using 2015 Edition Certified Electronic Health Record Technology (CEHRT) exclusively.
- Incorporate performance improvement in quality and cost performance scoring.
- Implement an optional facility-based scoring mechanism for facility-based clinicians.
- Create an Advancing Care Information performance category hardship exemption for small practices and add bonus points to the final score of clinicians in small practices.
- Add a new improvement activity for clinicians who attest to using Appropriate Use Criteria through a qualified clinical decision support mechanism for all advanced diagnostic imaging services ordered.
CMS also proposes various policies applicable to APM participation. For instance, CMS propose to:
- Extend the current revenue-based nominal amount standard through performance year 2020 (which allows an APM to meet the Advanced APM financial risk criterion if participants are required to bear total risk of at least 8% of their Medicare Parts A and B revenue).
- Modify policies regarding the timeframe for making qualifying APM participant determinations.
- Modify All-Payer Combination Option policies, which will be available beginning in performance year 2019.
- Revise the nominal amount standard for Medical Home Models.
CMS will accept comments on the proposed rule until August 21, 2017.