CMS Released Proposed Rule, Quality Payment Program (QPP) for 2018

The Centers for Medicare & Medicaid Services (CMS) released the Quality Payment Program (QPP) proposed rule for 2018 on Tuesday, June 20.  While we are only beginning to go through the proposed rule, all 1,058 pages, it does appear that CMS is concerned about the burden of participating in the program on small practices leading to a significant proposed rise in the low-volume threshold.

"We've heard the concerns that too many quality programs, technology requirements and measures get between the doctor and the patient," CMS Administrator Seema Verma said in a statement about the rule. "That's why we're taking a hard look at reducing burdens."

At a quick glance, here are some of the proposed changes:

•    Increasing the low volume threshold for MIPS participation to less than or equal to $90,000 in Medicare Part B charges or less than or equal to 200 Medicare Part B patients (up from $30,000 or 100 patients)
•    Adding a Virtual Group reporting option 
•    Weighting the cost performance category at 0% of the final score for payment year 2020 (giving CMS time to develop more episode groups) 
•    Providing more details regarding All-Payer Combination Options for Advanced APMs
•    Seeking comments on broadening the definition of Physician-Focused Payment Models to include payment arrangements with Medicaid or the Children’s Health Insurance Program (CHIP)
•    Shifting from describing the QPP as having three tracks (MIPS, APMs, AAPMs) to two tracks (MIPS and AAPMs).  

The QPP was created by CMS after Congress passed the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  Physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetist can all participate in the QPP through one of two tracks: (1) Merit-based Incentive Payment System (MIPS) and (2) Advanced Alternative Payment Models (Advanced APMs).  

Comments on the proposed rule are due on Friday, August 18, 2017.