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8 Takeaways from CMS Proposed Rule for Changes to MIPS in 2018

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Proposed MIPS Changes 2018

Not fully prepared for MIPS and feeling slightly overwhelmed? You’re not alone. According to a recent report, only 8 percent of physicians feel highly knowledgeable about the MIPS program halfway through the first performance year. Even more concerning, a reported 41 percent of physicians interviewed had never even heard of MACRA or the MIPS program. Which is why it might surprise you that the Centers for Medicare and Medicaid Services (CMS) already released a long list of proposed changes for the second program year in 2018.

However, most clinicians will likely be relieved to learn of the new changes – most of them aimed at aiding small practices, many of which have been struggling to adjust to the transition. CMS also opted to loosen some reporting restrictions and provide for new modes of participation.

So what exactly can you expect heading into 2018? Checkout our wrap-up of key takeaways from the Proposed Rule:


Small practices will see some of the biggest changes

Small practices will be the most affected by the proposed changes. CMS is seeking to expand the number of clinicians who will be exempt from MIPS by increasing the low-volume threshold. In 2017, clinicians that bill Medicare Part B more than $30,000 in allowed charges per year or provide care for more than 100 unique Medicare patients annually are eligible to participate. In 2018, however, the number of clinicians exempt from MIPS will increase. The new threshold will jump to $90,000 in Part B payments or 200 unique Medicare patients annually.

Performance Period Adjustments

CMS is lengthening the performance period for the Quality and Cost categories from 90 days in 2017 to the full year in 2018, though CMS will not use the Cost performance scores for final score determination. For the Improvement Activities and Advancing Care Information (ACI) categories, however, the 90-day performance period will remain the same.

Clinicians will have the option to join Virtual Groups

Virtual groups are new to the MIPS program in 2018. A Virtual Group is defined as a combination of 2 or more TINS who choose to participate together in MIPS. Virtual Groups have the flexibility to work with other groups or types of practices from any location. This could open the door for more clinicians to join the program and work with their peers, regardless of their geographical proximity. Learn more about Virtual Groups.

Small Practice Bonus

Small practices of 15 or fewer clinicians will be eligible to receive a Small Practice Bonus under the proposed rule. This bonus would add five points to a group’s score to help them meet MIPS requirements, as long as they submit data on at least one performance category in an applicable performance period.

Complex Care Bonus

Clinicians who provide medically complex care could be eligible to receive an adjustment by adding the average Hierarchical Conditions Category (HCC) risk score to their final score. Generally, this award would be between 1 to 3 points, based on the complexity of care provided, as determined by CMS.

EHR Requirements Slowed

In another reversal, CMS will allow the continued use of the 2014-edition Certified Electronic Health Record Technology in 2018, which was set to be phased out. This again is aimed at easing the burden for practices that are struggling to keep up with all the changes. Currently, many practices don’t have the resources or access to the 2015 CEHRT, which makes the transition very difficult. To encourage use of new EHR technology, CMS has proposed a scoring bonus for practices that use 2015 Edition CEHRT exclusively.

New Scoring Options for Facility-Based Physicians

Facility-based physicians, such as hospitalists, will have the option to use facility-based scoring for reporting. A facility-based clinician is defined as a clinician who provides at least 75 percent of their services in an inpatient hospital or emergency room setting. This includes many anesthesiologists and nurse anesthetists. Facility-based groups are defined as groups in which at least 75 percent of the individuals are facility-based clinicians. CMS hopes to align facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set would be applied to a clinician’s Quality and Cost performance categories.

Multiple reporting mechanisms per category allowed

For the first program year, CMS stipulated that for clinicians participating in MIPS, only one reporting mechanism is allowed per performance category (i.e. if a clinician is using a QCDR to report on a measure in the quality category, all measures in the quality category must be reported via QCDR). The Proposed Rule does away with this requirement and allows clinicians and groups to use whatever combination of reporting mechanisms that best suits their needs, regardless of category.


It is important to note that these changes to the MIPS program for 2018 are proposed changes. As a part of the federal rulemaking process, CMS is currently soliciting feedback from stakeholders and will issue a final rule in the coming months, which could include changes. Stay tuned!

To explore the proposed changes in depth, read the proposed rule here or checkout the CMS fact sheet.

What do you think about the proposed changes? Let us know in the comments below.

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