Highlights of the CMS Proposed Rule for the Quality Payment Program

Source: Emily Hill, PA, AAPM Coding Consultant
Date: August 8, 2018

The CMS Proposed Rule for the Quality Payment Program (QPP) addressed several key changes to the 2019 QPP. The Rule expands the definition of MIPS (Merit-Based Incentive Payment System) eligible clinicians to include physical therapists, occupational therapists, clinical social workers, and clinical psychologists and provides additional flexibilities for small physician practices.

It also adds an additional element for providers to quality for the low volume threshold and thus opt-out of the MIPS program. For 2019 a clinician must meet one of the following criteria:

  • ≤ $90,000 of Part B allowable charges
  • ≤ 200 Medicare beneficiaries
  • ≤ 200 Covered Professional Services

CMS also provides an “opt-in” option for those clinicians who meet or exceed one or two, but not all, of the low-volume threshold criteria. CMS also proposes to remove Part B drugs from the low-volume threshold determinations and from physicians’ payment adjustments.

CMS continues its Meaningful Measures Initiative by adding and removing a number of current quality measures. It also proposes to revise the definition of a high-priority measure to include quality measures that relate to opioids and to further clarify the types of outcome measures that are considered high priority. Quality now makes up 45% of a physician’s MIPS score.

For 2018, 10% of physicians MIPS score is tied to costs. This was to increase to 30% for 2019. Legislation passed earlier this year and supported by the AMA authorized CMS to weight costs at any level from 10% to 30% through the next three years. CMS is proposing to increase the cost weight to 15%in 2019 and then increase it by an additional 5% in each of the next two performance years until it reaches the maximum 30% in the 2022 performance year.

Advancing Care Information has been renamed to Promoting Interoperability (PI) and composes 25% of the MIPS score. The proposal requires physicians to use 2015 Certified Electronic Health Record Technology (CEHRT) and proposes a new scoring methodology. It also adds two new measures to the e-Prescribing objective: Query of Prescription Drug Monitoring Program and Verify Opioid Treatment Agreement.

Changes are also proposed to the Improvement Activities (IA) component which comprises 15% of a physician’s score. CMS proposes to maintain an attestation reporting option and a 90-day reporting period for the IA performance category. CMS is proposing 6 new IAs, modifications to 5 existing IAs, and removal of 1 existing IA.

View the CMS Fact Sheet on the MIPS Proposed Rule

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