Comments sought related to MACRA proposed rule

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The Centers for Medicare and Medicaid (CMS) is seeking comment related to the recently released Proposed Rule for CY 2018 Updates to the Quality Payment Program (QPP). The QPP was established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which began January 2017 as a transition year.

The proposed rule contains more than 1,000 pages and further aims to increase flexibility and reduce burdens by simplifying the program through continuing to offer support for doctors and clinicians especially in small, independent and rural practices. Also, it is looking to amend some existing requirements and introduce new policies to further encourage participation in either Advanced Alternative Payment Models (APMs) or the Merit-based Incentive Payment System (MIPS).

Some of the identified themes include:

  • Payment and delivery reform moving forward while maintaining the stance of reducing regulatory burden
  • Clinicians in small practices and Health Professional Shortage Areas (HPSA) would be exempt from participating in QPP
  • Changes in the low-volume threshold exclusions for Medicare Part B revenue and patient volumes from physician practices making less than or equal to $30,000 or that have seen less than or equal to 100 Medicare Part B patients to less than or equal to $90,000 in Medicare Part B revenue or caring for less than or equal to 200 Medicare Part B patients
  • Bonus points to practices with 15 or fewer clinicians, as well as to those providers that are deemed to care for a large volume of complex patient using the Hierarchical Conditions Category (HCC) risk score
  • Hospital Based Clinicians would be allowed to submit the facilities inpatient value-based purchasing score for calculating individual scores for cost and quality categories in MIPS
  • With the reopening and expansion of the Advanced Alternative Payment Model (AMP) track, CMS expects more clinicians will qualify in 2018 with maintaining quality faction criteria through 2019 and 2020 performance years
  • Cost category in MIPS would remain voluntary in 2018 performance year. However, in the 2019 performance year the category with have a 30-percent weight
  • Certified Electronic Health Record Technology (CEHRT) can remain at 2014 edition but with encourage to migrate towards 2015 edition. As well as adding in significant hardship exception to the advancing care information performance category of MIPS
  • Definition, guidance and technical assistance availability for a “virtual group” was also provided in the proposed rule

Please refer to the following to gather more information and/or submit a comment:

The 60-day comment period for the proposed rule ends on Monday, Aug. 21. https://www.regulations.gov/docket?D=CMS-2017-0082

A fact sheet on the proposed rule is available here. The proposed rule (CMS-5522-P) can be downloaded from the Federal Register.

For more information about the Quality Payment Program, please visit: www.qpp.cms.gov