MACRA final rule on the Quality Payment Program

On November 2, 2017 CMS released the final rule on the second year of the Quality Payment Program under the Medicare Access and Chip Reauthorization Act of 2015 (MACRA) . This initiative rewards the delivery of high-quality patient care and outcomes through the Merit-based Incentive Payment System (MIPS) and Advance Alternative Payment Models (APMs). Clinicians’ reimbursement is tied to evidence-based measures and advances in technology that contribute to better health information exchange.

CMS estimates the vast majority of eligible clinicians and groups will participates in MIPS, making it the default track again in 2018. Some of the changes for the second year include extending the period of quality reporting, delaying the mandate for 2015 Edition Certified EHR Technology, providing additional flexibility for small group practices and offering more details on how clinicians can receive credit for payment bonuses through Advance Alternative Payment models.

MIPS changes (effective January 1, 2018): • MIPS Cost performance category is now weighted at 10% of the total MIPS score, and the Quality performance category is now weighted at 50%. • The MIPS performance threshold is raised to 15 points in Year 2 (from 3 points in 2017). • Allowed use of 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in year 2 for the Advancing Care Information performance category and gives a bonus for using 2015 CEHRT. • One year minimum is established for reporting period for Quality measures. • 5 points on the final MIPS score awarded for treatment of complex patients. • 5 bonus points added to the MIPS scores of small practices • Less clinicians required to participate by excluding MIPS eligible clinicians or groups with less than or equal to $90,000 part B allowed charges, or less than or equal to 200 Medicare Part B beneficiaries.

Advance Payment Models changes (effective January 1, 2018): • Provides more detailed on how clinicians can receive credit for alternative payment bonuses through Advanced Alternative Payment models. • Extends the 8% revenue-based nominal amount standard that allows APMs to qualify as Advance APMs for two additional years.

Future Impact CMS estimates that 622,000 eligible clinicians will be subject to MIPS for the 2020 payment year. Because of the threshold increase, about 540,000 clinicians will be excluded from MIPS.

Assuming that 90 percent of MIPS eligible clinicians of all practice sizes participate in MIPS, CMS estimates $118 million dollars in positive adjustments and $118 million dollars in negative adjustments to ensure budget neutrality. There will be an additional $500 million available for providers who have final MIPS scores that meet or exceed the performance threshold of 70 points.

CMS continues the slow ramp-up of the Quality Payment Program by establishing special policies for the second year with the objective of encouraging successful participation in the program while reducing burden, reducing the number of clinicians required to participate and preparing clinicians for the CY 2019 performance year (CY 2021 payment year).

Resources: Breaking Down the MACRA Final Rule -Healthaffairs.org

CMS Quality Payment Program – Executive Summary