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FEDERAL | CMS Released 2018 Quality Payment Program Proposed Rule

Late last month, the Centers for Medicare and Medicaid Services (CMS) released the 2018 updates to the Quality Payment Program (QPP) Proposed Rule, setting policy for the second year of the program. New policy for the Merit-based Incentive Payment System (MIPS) encourages successful participation in the program and prepares clinicians for 2019. While the Agency believes a second transition period is necessary to build upon the iterative learning that was part of the 2017 "Pick Your Pace" program, each clinician will be expected to report, at minimum, for a continuous 90-day period in Year 2. Other physicians will be required to report up to and including the full CY 2018 (January 1 - December 31, 2018), depending on the MIPS category requirements.

In response to feedback, CMS offers some flexibilities for 2018, including a proposal to significantly expand the previously established low-volume threshold policy. According to the proposed rule, physicians who bill $90,000 or less in Medicare Part B charges or see 200 or fewer Part-B enrolled Medicare beneficiaries will be exempt from reporting. The proposal also allows individuals and groups to submit measures and activities through as many data submission mechanisms as necessary and will credit physicians for all reporting, regardless of the submission mechanism. To avoid a negative payment adjustment, physicians will be required to participate in the improvement activities and advancing care information performance categories for a minimum of a 90 continuous days within CY 2018, or up to and including the full CY 2018 depending on the size of their practice. A total performance threshold of 15 points has also been established.

This rule creates requirements for MIPS participation at the virtual group level, defined as a combination of two or more TINs from solo practitioners or a group with 10 or fewer eligible clinicians. These physicians must select one TIN to form a single virtual group with at least one other solo practitioner or group for a performance period of one year. Virtual groups will be assessed and scored across all four MIPS performance categories for the full performance period of one year. This will eliminate the burden for virtual group members so that they do not have to report as a virtual group as well as separately outside of the virtual group. To maintain flexibility, CMS has not proposed a limit on the number of TINs that may form a virtual group.

Although the proposal offers more flexibility than the previous year, ASPS will continue to advocate for the specialty by submitting comments to CMS.