2018 Quality Payment Program Final Rule
On Thursday, November 2, the Centers for Medicare and Medicaid Services (CMS) released the CY 2018 Updates to the Quality Payment Program (QPP) final rule. The final rule includes updates to the QPP for both the Merit-based Incentives Payment System (MIPS) and Advanced Alternative Payment Model (APM). CMS views the second year (2018) of the QPP as another transitionary year aimed to allow clinicians time to prepare for more robust program participation by year three (2019). The final rule included a comment period and was published with an Executive Summary and QPP Year 2 Fact Sheet. The Academy provided comments in response to QPP proposed rule for CY 2018.
It is important to note that audiologists are not eligible for participation in the QPP in the first two years (2017, 2018). The Secretary of the US Department of Health and Human Services (HHS) has the authority to include other professionals, including audiologists, beginning in 2019. This means that audiologists will not be required to report on anything in 2018, but will have the option to report on measures through MIPS voluntarily. The Academy has developed a fact sheet to assist audiologists with voluntary reporting under MIPS. The Academy is closely monitoring changes to the QPP to ensure audiologists are prepared for future participation.
MIPS Program Details
In the final rule, CMS is finalizing its policies for clinicians participating in the MIPS program. Most notably, after seeking public comment on a possible extension of a MIPS cost category weight of 0% for the 2018 performance year, CMS will instead weight the cost category at 10% to allow for a smoother transition to a 30% cost category weight for the 2019 performance year. The quality category is weighted at 50% in the 2018 performance year instead of at 60% as proposed in the proposed rule. An overview of the MIPS program details is below.
- MIPS Payment Adjustment: For the 2020 payment year, the payment adjustment ranges from - 5% to + 5% based on 2018 performance.
- Performance Period: A 12-month calendar year quality and cost performance period for the 2018 performance year/2020 payment year. This is an increase from the current 90-day requirement.
- MIPS Composite Score Categories: For the 2018 performance year:
- Quality: 50% - CMS maintains the same number of measures for quality reporting. There are no new cross-cutting measures.
- Advancing Care Information: 25% - CMS creates a hardship exception for small practices.
- Improvement Activities: 15% - MIPS eligible clinicians or groups must submit data on improvement activities via qualified registries, EHR submission mechanisms, QCDR, CMS Web Interface, or attestation.
- Cost: 10% - CMS will calculate information based on administrative claims data.
- Increase Low Volume Threshold: An increase in the low-volume threshold from <$30,000 to <$90,000 in Part B allowed charges OR from <100 to <200 Part B beneficiaries so that more small practices and eligible clinicians in rural and Health Professional Shortage Areas (HPSAs) are exempt from MIPS participation.
- Addition of Virtual Groups: A new participation option for year 2, which will be composed of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” with at least one other such solo practitioner or group to participate in MIPS for a performance period of a year.
Voluntary Reporting/Feedback Reports
Audiologists are still able to report voluntarily in 2018. CMS will provide performance feedback to eligible clinicians and groups that do not meet the definition of a MIPS qualified clinician but freely report on measures and activities under MIPS. This input will apply to data collected in the 2017 performance period that would be available beginning July 1, 2018.
CMS is finalizing additional flexibility for submitting data through multiple submission mechanisms, something that the Academy strongly supported in our proposed rule comments. Individual MIPS eligible clinicians or groups will be able to provide measures and activities, as available and applicable, via as many mechanisms as necessary to meet the requirements of the quality, improvement activities, or advancing care information performance categories for the 2019 performance period. This option will provide clinicians the ability to select the measures most meaningful to them, regardless of the submission mechanism.
Advanced APM Program Details
CMS expects new Advanced APMs to be available in the coming year and estimates that 185,000 to 250,000 clinicians may become Qualifying APM Participants (QPs) in the payment year 2020 (based on the performance year 2018). QPs are eligible clinicians in Advanced APMs that have, through an Advanced APM, met the threshold percentage of their patients or payments; they can also reach QP status through the All-Payer Combination Option.
Those that have QP status for a year are exempt from the MIPS reporting requirements and payment adjustment for the year. Also, they receive a 5% APM Incentive Payment from 2019 through 2024. Eligible clinicians participating in Advanced APMs who do not meet the QP or Partial QP thresholds must comply with MIPS reporting requirements and payment adjustments (unless they are excluded from MIPS).
Advanced APM Requirements
For the 2019 and 2020 performance periods, the Agency is maintaining the applicable revenue-based nominal amount standard at 8%.
All-Payer Combination Option
The All-Payer Combination Option will begin to apply in 2019. This option makes QP determinations based on an eligible clinician’s participation in Advanced APMs and Other Payer Advanced APMs. To qualify, a qualified clinician must participate in both APMs as mentioned above.
The Academy continues to assess the role that audiologists may play in APMs and will keep members updated as we learn more. The Academy anticipates that when eligible, the most audiologist will participate in the QPP via the MIPS track.
NOTE: CMS has updated and moved its QPP resource library. Click the here for detailed information on all aspects of the QPP.