The Centers for Medicare and Medicaid Services (CMS) recently released the final rule outlining the Quality Payment Program (QPP) for 2018. While nearly identical to 2017, there are some new changes that could have a large impact on participating practices and clinicians. How will these new changes affect you? Check out our list of FAQs and get in touch to learn how SurveyVitals can help your organization meet reporting requirements.
If you bill Medicare Part B more than $90,000 in allowed charges per year and provide care for more than 200 unique Medicare patients a year, then you are part of the QPP. If you do not meet this threshold, you could be exempt from participating in the program in 2018 under the the low-volume threshold exemption.
Eligible clinicians under the program include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. If you are unsure if you are required to participate in MIPS, CMS has provided a resource to check your status by entering your NPI into an eligibility “calculator”. Additionally, the agency plans to send letters to clinicians notifying them of their eligibility in 2018.
**Note: CMS has not yet updated the QPP website and tool to reflect the 2018 performance year.
There are two participation tracks in the Quality Payment Program. Most Medicare Part B clinicians and groups will fall under the Merit Incentive Payment System (MIPS) track, while a smaller percentage will qualify to participate in the Alternative Payment Models (APM) track if considered an “advanced APM.” It is important to note that those APM models which are not considered “advanced” by CMS will still participate in the MIPS track.Learn more about APMs here.
You will receive a performance-based adjustment to your Medicare fee schedule in 2020 based on your performance in 2018. The amount of the adjustment, either positive, negative or neutral, is based on an eligible clinician or group’s Composite Performance Score (CPS). The CPS is calculated using data across four categories of measurement:
See the weighted breakdown by category per program year below.
For the 2018 performance year, CMS extended a portion of the “pick your pace” program, allowing clinicians to submit just 90-days of performance data for the required measures in the Advancing Care Information and Improvement Activities categories. However, clinicians will need to report data on all required measures in the Quality category for the full performance year (12 months).
CMS will also score and measure the Cost Category for the full 12 month period as well. Since CMS gathers the Cost Category information through Medicare claims data, no additional submission mechanism is required. If you do not participate in MIPS in 2018 you could be faced with a 5% penalty.
Eligible clinicians have the option to report as an individual, within a group, or within a virtual group. If reporting as an individual (single NPI tied to a single TIN), eligible clinicians can send individual data for each of the MIPS categories through their EHR, registry, QCDR, or via attestation and will receive a single composite performance score. CMS will also accept quality data through routine Medicare claims processing, if applicable.
Eligible clinicians can also submit data as a group, which CMS defines as a single Taxpayer Identification Number (TIN) with 2 or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their National Provider Identifiers (NPI), who have reassigned their Medicare billing rights to the TIN. Participants will be scored as a group and will receive one payment adjustment based on aggregate performance. Group-level data can be submitted for each MIPS category through the CMS web interface (optional for groups of 25+), an EHR system, registry, QCDR, or by attestation.
The third option, new to the MIPS program in 2018, is participating via a virtual group. A Virtual Group is defined as a combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of 10 or fewer eligible clinicians that elect to form a virtual group for a performance period for a year. There is currently no limit on the number of TINs that can participate in a virtual group (i.e. one provider might have multiple TINs from multiple practice locations and can form a virtual group as a solo practitioner). Virtual Groups bring additional flexibility to the program, allowing clinicians to participate in MIPS with their peers, regardless of their geographical proximity or specialty. Those wishing to participate in a MIPS Virtual Group must make a formal election with CMS by December 31, 2017. Learn more about virtual groups here.
The aim of the MIPS program is to provide clinicians and groups with the flexibility to select measures that best suit their practice. Providers can select measures to report on in each category from the list of CMS-approved MIPS measures, which can be found on the QPP website here . Alternatively, clinicians and groups can select to report specialized measures in the Quality Performance Category developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDRs were established in 2014 as a part of the PQRS program and have the ability to develop and support specialty-specific measure sets that can be reported in lieu of the traditional MIPS measures. QCDR measures must be approved each year by CMS. The 2018 list of approved QCDR measures has not yet been published by the agency. Check back for updates.
Eligible clinicians are required to report 6 measures of their choosing for the quality category. One of those measures must be an outcome measure. If no outcome measure is available, a ‘high priority’ measure must be reported in its place. High priority measures are contained in the following domains: appropriate use, patient safety, efficiency, patient experience, and care coordination.
CMS developed specialty measure sets as a part of the available MIPS measures in the Quality Category. Participating clinicians must choose six measures to report within their specialty set. If there are fewer than six Quality measures to choose from in a specialty set, the clinician or group must complete all available measures contained in the set.
The IA category requires clinicians to participate in a combination of measures totaling forty points to fully satisfy reporting requirements. Activities that are weighted “high” are worth 20 points, while “medium” weighted activities are valued at 10 points. Clinicians and groups considered non-patient facing and those practices with 15 or fewer eligible providers and/or clinicians practicing in rural and health professional shortage areas may faced reduced reporting requirements.
The Advancing Care Information category places an emphasis on interoperability and patient engagement with certified EHR technology. Eligible clinicians must meet five required measures in the Advancing Care Information category, with the opportunity to earn additional bonus points for up to 9 total measures. Clinicians will report based on the level of their certified electronic health record. In 2018, CMS will allow organizations to use either the 2014 or 2015 Edition CEHRT, but will grant a bonus for using the 2015 Edition CEHRT.
In addition to supporting our clients in the Improvement Activities category, SurveyVitals anticipates being able to help anesthesia clients who utilize a Qualified Clinical Data Registry (QCDR) meet a measure in the Quality performance category. Learn more here.
|Low volume threshold.||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 MIPS.||Clinicians that bill Medicare Part B more than $90,000 in allowed charges per year or provide care for more than 200 unique Medicare patients annually are eligible to participate in MIPS.|
|Performance Period Adjustments||Quality: 90 days Cost: 90 days Advancing Care Information: 90 days Improvement Activities: 90 days||Quality: Full year Cost: Full year Advancing Care Information: 90 days Improvement Activities: 90 days|
|Virtual Groups||No virtual groups||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.|
|Small Practice Bonus||N/A||Small practices of 15 or fewer clinicians are eligible to receive five points to their 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||N/A||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 is be between 1 to 3 points, based on the complexity of care provided, as determined by CMS.|
|EHR Requirements||N/A||Facility-based physicians, such as hospitalists, have the option to use facility-based scoring. CMS aligns facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set will be applied to a clinician’s Quality and Cost performance categories.|
|Facility-Based Physicians||N/A||Facility-based physicians, such as hospitalists, have the option to use facility-based scoring. CMS aligns facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set will be applied to a clinician’s Quality and Cost performance categories.|
Yes! SurveyVitals, with our CMS-approved vendor partner, Novaetus Inc., is ready to administer CAHPS for MIPS on behalf of your organization in 2018. Contact us at email@example.com to learn more about our CAHPS program.
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