AMA: Much of 2018 QPP proposal based on its input

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AMA: Much of 2018 QPP proposal based on its input 

The American Medical Association (AMA) says that a lot of the policies that are included in the proposed final Medicare Quality Payment Program (QPP) rule for the 2018 performance year that was recently released by the Centers for Medicare and Medicaid Services (CMS) are based on AMA’s recommendations.

AMA reports that, “In essence, [CMS] is providing another transition year. CMS is also proposing a number of policies to help small practices. In sum, CMS estimates that under this proposed rule more than 94 percent of eligible clinicians would earn either a positive or neutral payment adjustment [for the 2018 performance year].”

The following is an AMA summary of highlights from the proposed rule. The underlined bullets signify AMA’s recommendations. 

Additional accommodations for small practices

Significantly expands the low-volume threshold to $90,000 or less in Medicare Part B allowed charges or 200 or fewer Medicare Part B patients (the previous threshold was $30,000 in allowed charges or 100 patients); CMS estimates that just 37 percent of clinicians who bill Medicare will be subject to MIPS.

Creates virtual groups to assist small practices.

Adds five bonus points to the final MIPS scores for practices of 15 or fewer clinicians.

Adds a hardship exception from the Advancing Care Information (previously Meaningful Use) category for practices of 15 or fewer clinicians.

Advancing Care Information

Allows the use of the 2014 edition of certified electronic health records technology (CEHRT) past 2017; CMS will not mandate that physicians update their EHR in 2018.

Increases opportunities for bonus percentage points.

Permits physicians to continue to report on Modified Stage 2 measures in 2018 instead of new Stage 3 measures.

Quality

Increases the quality performance category weight to 60 percent in 2018 (due to the “Cost” category weight remaining at zero in 2018).

No additional cross-cutting measure requirements added in 2018.

Maintains data completeness threshold at 50 percent in 2018. (Measures that do not meet data completeness will receive one point, except small practices – which will receive three points per measure).

Maintains three-point floor for measures scored against a benchmark, measures that do not have a benchmark, and measures that do not meet the case minimum.

New and modified specialty measure sets for the 2018 performance period, including the removal of cross-cutting measures from most of the specialty sets (only retained in family practice, internal medicine and pediatrics specialty sets).

Maintains the number of quality measures a physician must report for full participation in the “Quality” performance category. (AMA asked that physicians be required to report even fewer quality measures in 2018).

Proposes a phased-in approach to identify and remove topped out measures

Cost category

CMS proposes a zero weight for costs again in the 2018 performance/2020 payment year, which would rise to 30 percent the following year. CMS is also seeking comments on whether to stick with its prior plan to weight the category at 10 percent next year.

10 previously-finalized, episode-based cost measures will be replaced in the future with measures developed with more input from clinical experts and stakeholders.

Physicians will receive information on how they would have scored under the two current, value-based modifier measures (total costs per beneficiary and spending from three days before to 30 days after hospital admission) – which the AMA has opposed, but the scores will not count if the zero weight is finalized.

Improvement activities (IA)

CMS continues to allow physicians to report on IA through simple attestation.

The proposed rule creates stability in program requirements by not changing the number of IA physicians must report.

It also develops additional IA, including adding two activities related to diabetes prevention programs, and it clarifies existing IA to be inclusive of additional activities.

Alternative Payment Models (APM)

The revenue standard for more than nominal financial risk remains at eight percent of revenues.

Other payer APM also have access to the 8 percent of revenues standard for more than nominal risk.

Participants in the one medical home model currently recognized as an Advanced APM, CPC+ will not be excluded from the medical home risk standard if they have more than 50 clinicians.

The Physician-focused Payment Model committee may consider APM for which Medicaid is a payer even if Medicare is not.