MACRA Quality Payment Program: MIPS 2018

mips 2018 program

What is the Quality Payment Program?

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.


Who Participates?

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.

Two Tracks: Which is right for you?

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.

The MIPS track

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:

  1. Quality
  2. Advancing Care Information
  3. Clinical Practice Improvement Activities (commonly referred to as Improvement Activities)
  4. Resource Use (cost)

See the weighted breakdown by category per program year below. To learn more about MIPS scoring, click here.

Calculating Your MIPS Score

How do I avoid a negative payment adjustment?

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.

Individual vs. Group Reporting

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.

Accepted MIPS Reporting Mechanisms

Selecting Measures

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 (https://goo.gl/yWMJJJ). 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.

Quality Category

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.

What are specialty measure sets?

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.

Clinical Practice Improvement Activities (IA)

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. Learn more about these special exemption statuses here.

Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at info@surveyvitals.com to learn more.

Requirements or MIPS Participation by Category

Advancing Care Information

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.

For anesthesia clients

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.

  • – AQI 48 (anesthesia patient experience)

How is MIPS different in 2018?

Category 2017 2018
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.

Does SurveyVitals administer CAHPS for MIPS?

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 info@surveyvitals.com to learn more about our CAHPS program.

Interested in meeting measures with SurveyVitals

Want to learn how SurveyVitals can help you prepare for MIPS? Subscribe to our MIPS update list below or email us at support@surveyvitals.com. You can also send us a message using the blue chat icon below to speak to a member of our support team.

*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.

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June 4th, 2018 Categories: Ambulatory and Outpatient Surgery, Anesthesia, CAHPS Surveys, Emergency Medicine, MIPS, Neonatology, Outpatient Practice, Radiology, Urgent Care

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MIPS 101 for Anesthesia Providers

MIPS anesthesiologist

Are you an anesthesia provider participating in the Merit-Based Incentive Payment System (MIPS)? Let us tell you how the SurveyVitals solution might help you fulfill certain reporting requirements.

What is MIPS?

The Merit Incentive Payment System (MIPS) is one of two tracks in the QPP, the quality payment incentive program implemented by CMS. A small percentage of clinicians will qualify to participate in the Alternative Payment Models (APM) track, but most anesthesiologists will fall under the MIPS track.

You will receive a performance-based adjustment to your Medicare fee schedule in 2020 based on your MIPS 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.

Who participates?

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. To determine 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.”

How are measures reported?

Anesthesiologists have the option to report as an individual, within a group, or within a virtual group.

Individual Single NPI tied to a single Tax Identification Number (TIN)
Group Single TIN with two or more eligible clinicians, including at least one MIPS-eligible clinician, as identified by their National Provider Identifiers (NPIs), who have reassigned their Medicare billing rights to the TIN
Virtual Group Combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of ten or fewer eligible clinicians

Reporting mechanisms vary based on reporting type and measure category. You can find more information on reporting mechanisms here.

How are measures selected?

Anesthesia providers and groups can select measures from the list of CMS-approved MIPS measures at the QPP website. Alternatively, they may select to report on Quality performance using specialized measures developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDR measures must be approved each year by CMS. The 2018 list of approved measures can be found here.

Quality Category

Anesthesiologists are required to report on six measures of their choosing for the quality category. One of those measures must be an outcome measure.

SurveyVitals is equipped to help anesthesia clients utilizing a QCDR to meet an outcome measure (AQI48 – Patient-Reported Experience with Anesthesia) in the Quality category. You must sign a disclaimer in order to report your patient experience data to a QCDR. View the reporting checklist, quick facts, and important deadlines here.

Improvement Activities (IA) Category

Anesthesia providers are required to participate in a combination of IA measures totaling 40 points. “High-weighted” activities are worth 20 points, while “medium-weighted” activities are valued at ten points. Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at info@surveyvitals.com to learn more.

Reporting requirements for Improvement Activities are reduced for non-patient facing clinicians, which are defined as either:

Those considered non-patient facing must participate in one high-weighted activity or two medium-weighted activities to satisfy the Improvement Activities category (for a total of 20 points rather than 40).

Always remember to check the eligibility calculator on the QPP website to confirm you are considered non-patient facing.

Promoting Interoperability Category

The Promoting Interoperability (formerly 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 Promoting Interoperability category, with the opportunity to earn additional bonus points for up to 9 total measures.

Many anesthesiologists are exempt from fulfilling the Promoting Interoperability requirements due to having hospital-based special status. CMS defines a hospital-based clinician as a MIPS-eligible clinician who furnishes 75 percent or more of his or her professional services in a site of service identified by the following Place of Service (POS) codes used in HIPAA standard transactions:

Always remember to check the eligibility calculator on the QPP website to confirm you are considered hospital-based.

Cost Category

The score for the Cost category is calculated using administrative claims data. No data submission is required.

Does SurveyVitals administer CAHPS for MIPS?

Yes! SurveyVitalsis ready to administer CAHPS for MIPS on behalf of your organization in 2018. Contact us at support@surveyvitals.com to learn more about our CAHPS program.

Interested in meeting MIPS measures with SurveyVitals?

Want to learn how SurveyVitals can help you prepare for MIPS? Subscribe to our MIPS update list below or email us at support@surveyvitals.com. You can also send us a message using the blue chat icon below to speak to a member of our support team.

*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.

June 3rd, 2018 Categories: Anesthesia, MIPS

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Virtual Groups for MIPS 2018

MIPS Virtual Groups 2018

An important deadline is approaching for groups and physicians participating in MIPS in 2018. December 31 marks the last day for clinicians to notify CMS that they are electing to participate in a Virtual Group for MIPS 2018.

If you aren’t familiar with Virtual Groups, you aren’t alone. Virtual Groups are a brand new option for MIPS participants in 2018 (Just one of several changes that CMS is implementing – check the details in this blog post). These Virtual Groups allow clinicians from around the country to team up with each other to help satisfy MIPS requirements.

To help groups and clinicians prepare to participate in a Virtual Group in 2018, we have compiled some FAQ about the program from the final rule published by CMS.

What is 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 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.

What is the deadline to notify CMS about a Virtual Group?

Individual MIPS eligible clinicians or groups electing to be in a Virtual Group must make their election prior to the start of the applicable performance period and cannot change their election during the performance period. The deadline for such an election was recently extended to December 31, 2017.

Can me or my group participate in multiple Virtual Groups?

No. Each eligible clinician or group may only elect to be in one Virtual Group at a time. In the case of a group, the election applies to all MIPS eligible clinicians (NPIs) in the group.

How are Virtual Groups identified for reporting purposes?

Each MIPS eligible clinician who is part of a Virtual Group will be identified by a unique Virtual Group participant identifier. This unique identifier is composed of a combination of the following identifiers: 1) Virtual Group identifier (established by CMS) 2) TIN number and 3) NPI number.

Are there different reporting requirements for Virtual Groups?

Virtual Groups have the same reporting requirements as other MIPS participants. There are still special exceptions for non-patient facing practices, small practices, rural practices, and practices with HSPA status. For the most part, policies that apply to regular group reporting also apply to virtual group reporting.

What are the steps to form a Virtual Group?

1. Determining eligibility – Contact TA representative

2. Executing formal written agreements – TINs comprising a virtual group must establish a written formal agreement between each member of a virtual group prior to election

3. Submitting formal election registration – On behalf of the virtual group, the official designated virtual group representative must submit an election by December 31, 2017. – Such an election will occur via email to the Quality Payment Program Service Center using the following email address: MIPS_VirtualGroups@cms.hhs.gov – Submission must include, at a minimum, information pertaining to each TIN and NPI associated with the virtual group and contact information for the virtual group representative. – Each TIN associated w/the virtual group – Each NPI associated with the virtual group – Name of the virtual group representative – Affiliation of the virtual group representative to the virtual group – Contact information for the virtual group representative – Confirmation through acknowledgement that a formal written agreement has been established between each member of the virtual group (solo practitioner or group) prior to election and each eligible clinician is aware of participating in a MIPS virtual group for an applicable performance period. – Each party must retain a copy of the virtual groups written agreement and is subject to the MIPS data validation and audit process.

4. Allocating resources for virtual group implementation and related activities

If approved to participate in a virtual group, CMS will contact your group representative via email to notify them of their status and issue a virtual group identifier for performance.

How to formally elect to participate in a Virtual Group?

CMS released a Virtual Group Toolkit to get started with the election process. It can be downloaded here.

Can SurveyVitals help meet MIPS requirements?

Yes! SurveyVitals is a CMS-certified CAHPS vendor ready to administer CAHPS for MIPS. Additionally, SurveyVitals can help organizations meet 6 different Improvement Activities to satisfy MIPS requirements. And if you are an anesthesiologist, we can also help you meet a measure in the Quality Category via QCDR reporting.

Where to start?

Schedule a demo today to learn more about how SurveyVitals can help with MIPS in 2018.

November 27th, 2017 Categories: featured, MIPS

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Do Not Miss This MIPS Reporting Deadline

MIPS 2017
Avoiding A MIPS Negative Payment Adjustment

October 2nd marks the very last day for eligible clinicians to start collecting MIPS data for partial year submission. If this fall reporting deadline is missed, clinicians and/or groups will not be eligible to receive a positive payment adjustment in 2019. Rather, they will be faced with two outcomes:

  1. Submit the minimum amount of data and receive a neutral payment adjustment
  2. Submit no data and receive a downward payment adjustment (up to -4%)

Given the flexibility of the MIPS program this year, it would be a missed opportunity for groups and clinicians to submit just 90-days of performance data to Medicare to earn a moderate positive payment adjustment – maybe even the max adjustment – in 2019. Learn more about MIPS and “Pick Your Pace” here.

MIPS Pick Your Pace

While it might seem a bit daunting if you haven’t started, there is still a short window of time for you and/or your group to select the required number of measures and get up and running before the partial submission deadline passes.

Partial Submission Pace

In order to participate in the ‘partial submission’ pace as outlined by the Centers for Medicare and Medicaid Services, eligible clinicians and groups will need to submit 90 consecutive days worth of performance data to Medicare across the following MIPS scoring categories:

For clinicians in rural or health professional shortage areas, or for those clinicians considered non-patient facing or “hospital-based,” you may face reduced reporting requirements. Learn more about these special status groups under MIPS here.

Selecting A Submission Mechanism and Measures

Submission methods may vary based on the measure. CMS has provided this chart to help groups and clinicians find the right reporting method for each category.

MIPS Submission Methods
Meeting Measures with SurveyVitals

Finally, SurveyVitals can help you meet a number of measures in the Improvement Activities category, including a high-weight activity. Additionally, SurveyVitals can submit data to your QCDR and help you administer CAHPS for MIPS. Want to learn more about meeting MIPS measures with SurveyVitals? Contact us at info@surveyvitals.com

September 15th, 2017 Categories: Anesthesia, featured, MIPS, Outpatient Practice

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

MIPS Year 2 Proposed Rule
Ready or not: MIPS 2018 Proposed Rule

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 changes in the proposed rule for MIPS 2018.

However, most clinicians will likely be relieved to learn of the new changes. With most of the changes 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 in the proposed rule.

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

1. 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 2018 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.

2. 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 MIPS 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.

3. Clinicians will have the option to join Virtual Groups

Virtual groups are new to the MIPS 2018 program year. 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.

4. 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.

5. 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 MIPS 2018 score. Generally, this award would be between 1 to 3 points, based on the complexity of care provided, as determined by CMS.

6. EHR Requirements Slowed

In another reversal, CMS will allow the continued use of the 2014-edition Certified Electronic Health Record Technology in MIPS 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.

7. 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.

8. 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.

Interested in learning more about SurveyVitals? Click here to sign-up for a free, no hassle product.

July 27th, 2017 Categories: Anesthesia, featured, MIPS, Outpatient Practice

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