On Thursday, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2018 Medicare Quality Payment Program (QPP) final regulation. This regulation outlines the requirements for year 2 of the Merit-based Incentive Payment System (MIPS), as well as for qualified or “Advanced” Alternative Payment Models (APMs) under MACRA.
ACG is currently reviewing the final rule’s impact upon clinical GI, and will share more details in later communications. For immediate consideration, here is a brief overview and top-line summary.
CMS provided a side-by-side comparison that summarizes the final changes to the requirements for MIPS and APMs for calendar year 2018 compared to 2017.
CMS estimates that there are 11,298 MIPS-eligible GI clinicians. According to CMS estimates, 3% would receive a reimbursement cut in CY 2020, while 97% would be eligible for a bonus, or at least avoid a payment cut.
The estimates for small practices are not as positive: CMS approximates that there are 116,626 MIPS-eligible clinicians in practice sizes 1 to 15. Of these practices, 9% are expected to receive a payment cut.
The maximum payment cut for the 2020 payment year is 5% for those who do not report MIPS measures in CY 2018. This is a deeper cut from the 4% payment adjustment for not participating in MIPS in 2017, which impacts the payment for CY 2019.
ACG Advocacy Paying Off – Exemptions for Hard Hit Hurricane Areas
In Thursday’s final rule, CMS announced establishing an automatic “extreme and uncontrollable circumstance” policy for the 2017 MIPS performance period that recognizes recent hurricanes (Harvey, Irma, and Maria) and other natural disasters can effectively impede a MIPS eligible clinician’s ability to participate in MIPS. ACG has advocated CMS to do this so we are very encouraged that CMS listened to the College in announcing this policy change.
What does this change in 2018 Final Rule mean for 2017 Reporting Year?
- Clinicians in affected areas who do not submit data will not receive a payment cut in CY 2019.
- Clinicians who do submit data will be scored on their submitted data.
- The policy applies to individuals (not group submissions), but all individuals in the affected area will be protected for the 2017 MIPS performance period.
- This policy does not apply to APMs.
MACRA Final Rule Top-Line Summary
Impact on Smaller and Rural GI Practices
According to CMS, many small practices did not have to participate in MIPS during the 2017 transition year due to the low-volume threshold. For the CY 2017 performance period, the agency set this threshold at less than or equal to $30,000 in Medicare fee-for-service allowed charges, or less than or equal to 100 Medicare fee-for-service patients.
CMS will implement additional flexibilities for small practices in CY 2018, including:
- increasing the low-volume threshold to less than or equal to $90,000 in Medicare fee-for-service allowed charges, or less than or equal to 200 Medicare fee-for-service patients;
- adding a significant hardship exception from the Advancing Care Information performance category for MIPS-eligible clinicians in small practices;
- providing 3 points, even if small practices submit quality measures below data completeness standards;
- and providing additional bonus points to the final scores of MIPS-eligible clinicians who are in small practices.
Quality Payment Program Year 2: MIPS
ACG is dismayed that CMS decided to change some MIPS scoring weights – further complicating the formula for MIPS.
- Quality 50% for CY 2018 (CMS originally proposed to keep this at CY 2017 weight of 60%)
- Cost 10% (CMS originally proposed to keep this at CY 2017 weight of 0%)
- Improvement Activities 15% (same as 2017); and
- Advancing Care Information 25% (same as 2017)
For 2018, the minimum performance threshold for MIPS is set at 15 points, with the “exceptional performance” bonus threshold set at 70 points.
Quality Payment Program Year 2: APMs
CMS noted that the agency is taking steps to increase participation in Advanced APMs. Specific policies include:
- extending the 8% generally applicable revenue-based nominal amount standard that allows APMs to qualify as an Advanced APM for two additional years, through performance year 2020; and
- making it easier for clinicians to qualify for incentive payments by participating in Advanced APMs that begin or end in the middle of a year.
CMS estimates that approximately 185,000 to 250,000 eligible clinicians may qualify for Advanced APM participation in CY 2018 for the 2020 payment year.
Stay tuned for more information on the 2018 final rule as we delve into the details and share our analysis.
ACG hosts a wealth of educational material on the National Affairs section of the ACG website: Making $ense of MACRA.
Remember: Your 2017 reporting impacts your CY 2019 Medicare payments. ACG members are encouraged to use the College’s various MACRA resources, including the detailed overview of MACRA, “ACG’s “Making $ense of MACRA,” the ACG-CMS webinar on MIPS program, ACG’s “quality reporting checklist,” a list of each measure in the MIPS Quality, Advancing Care, and Improvement Activities categories, as well as each measure’s specifications. Check out the comprehensive list of ACG’s “MACRA Tidbit for the Week” here as well.
Whitfield L. Knapple, MD, FACG
Chair, ACG Legislative and Public Policy Council