CMS dropped their Final Rule for the new Medicare Quality Payment Program on October 14, 2016, two weeks earlier than most the industry expected to see it.
The full Final Rule document clocks in at 2,171 pages, jam-packed with all the details of the new MACRA MIPS and Advanced APM programs.
We looked through the legislation to find the key changes CMS made to MIPS since the Proposed Rule was released back in April. Here are some of the most significant changes. Spoilers ahead!
The Low-Volume Threshold Changes.
The Final Rule revises the exemption criteria. Clinicians with $30,000 or less in Part B allowable charges, or 100 or less Part B-enrolled benficiaries are now excluded from MIPS. This will exclude more than 380,000 clinicians per CMS.
However, if your organization opts for Group Reporting, low-volume clinicians under your tax ID number are back on the hook.
The Hospital-Based Provider Definition is Revised.
The “Hospital-Based Clinician” definition was broadened by two factors.
First, if the clinician providers 75% or more of their covered services in a hospital-based facility, they are considered “hospital-based.” It was previously set at 90%.
Additional, POS 22 (on-campus outpatient hospital) now is considered a hospital-based location. Now POS 21, 22, and 23 are all considered to be hospital-based.
An advantage for hospital-based providers is that they can receive a zero based weight for the “Advancing Care Information” category. As a result, they can opt out of reporting the Meaningful Use-type measures without impacting their overall score.
The Reporting Period is Shortened.
CMS now requires just a 90 day reporting period to quality for the maximum incentive.
This was less than clear in the CMS first webinar following the Final Rule release. While they repeatedly emphasized that a full year is ideal, they did say, verbatim: “A full year gives you the most measures to pick from. BUT if you report for 90 days, you could still earn the max adjustment.”
There are no bonus points in the Final Rule for reporting for longer than 90 days. You’ll need to evaluate for your own practice whether reporting for longer than 90 days generates a better score for a selected measure.
CMS indicates that there will be a three month reporting period for the ACI category in 2018 as well.
There are a couple exceptions in the Final Rule related to specific Group Reporting options. For example, participation in CAHPS may require a full year reporting period for that measure.
The Penalty is Easier to Avoid.
Just dipping your toe in the water for now?
Practices that hit the “minimum threshold” of three points can avoid the penalty.
You can hit this threshold by reporting one quality measure, or one improvement activity, or the five Advancing Care Information measures.
Less Improvement Activities are Required for a Maximum Score.
In the Final Rule, the Clinical Practice Improvement Activities category has been shorted to “Improvement Activities.”
On a more helpful note, the scores were re-weighted as well. Practices can now hit the maximum score with four medium priority activities (instead of six) or two high priority activities (instead of three.)
CMS clarifies that activities already in place in a practice are completely acceptable.
Some Concessions are Made for Rural Health and HPSAs.
Practices in a Small, Rural, or Health Professional Shortage Areas have a reduced target for improvement activitites. They can hit the maximum score with just one high-weighted activity or two medium-weighted activities.
The Cost Performance Category is Off the Table for Year One.
The Cost Performance Category has been re-weighted to zero for 2017.
For many, this could have proven to be the hardest category to calculate in advance. While the pressure is off for the first year, CMS indicates that they will still provide a scorecard to clinicians. Practices will have the opportunity to study and learn from how they would been scored.
As the original MACRA legislation requires a gradual shift in scoring – from a Quality emphasis to a Cost emphasis – this category will be right back on the table in a big way in the coming years.
Non-Physicians Can Opt Out of the ACI Category.
With a nod to the feedback they received on the proposed rule, CMS reduced requirements for Non-Phyicians – nurse practitioners, physician assistants, clinical nurse specialists, and certified registered nurse anesthetists. They may opt out of the ACI performance category without negatively impacting their score.
ACI Has Been Reduced to 5 Core Activities.
The Advancing Care Information category (previously known as Meaningful Use) has been reduced to five required measures, down from eleven. Briefly, the five are as follows:
- Security Risk Assessment
- ePrescribing
- Provide Patient Access (Bonus Potential for Performance)
- Send a Summary of Care (Bonus Potential for Performance)
- Request / Accept Summary of Care (Bonus Potential for Performance)
When we get into the details of the MIPS scoring, it becomes clear that practices will probably still want to select a couple additional measures. Hitting the basic five, even with strong performance, can leave a clinician falling short of the potential max score. More to come regarding MIPS score optimization in future articles.
The Cross-Cutting Requirement is Gone.
For the Quality Performance Category, the requirements stayed fairly consistent with the proposed rule. However, CMS did eliminate the requirement to select one Cross Cutting measure. An Outcome measure is still required.
In upcoming articles, we will dig into some critical areas:
- Keys to Eligibility Determination.
- Decision Time: Group Reporting vs. Individual Reporting.
- How to Master the MIPS Scoring Puzzle.
Questions? Other observations? Please leave a comment.
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