CMS recently announced a proposed rule that would modify MACRA’s Quality Payment Program during its second performance year to ease provider burdens and continue to ramp up full participation in the program.
A major proposed change would be to increase the Quality Payment Program participation threshold. The federal agency stated that the new rule would exclude eligible clinicians or groups with less than $90,000 in Medicare Part B allowable charges or less than 200 Medicare beneficiaries.
The original MACRA implementational rule threshold was less than $30,000 in Medicare Part B revenue and less than 100 beneficiaries.
CMS also plans to ease Quality Payment Program burdens by implementing virtual groups. The groups, which are not currently available in the first performance year, would include solo practitioners and groups of ten or fewer eligible clinicians who agree to partner virtually with their peers to participate in the Quality Payment Program’s Merit-Based Incentive Payment System (MIPS).
The virtual nature of the groups allow eligible clinicians to collaborate regardless of location or specialties.
In addition, CMS plans to reduce burdens by establishing two bonus point options. THe first would adjust eligible clinician performance scores in MIPS by up to 3 bonus points for treating medically complex patients.
The second bonus point opportunity would boost the MIPS composite scores of any eligible clinician or group who is in a small practice of 15 or fewer clinicians. The clinicians or group would receive 5 bonus points as long as the clinicians submit data on at least one performance category.
Additionally, the proposed rule contained changes to both value-based reimbursement tracks under the Quality Payment Program: MIPS and the Advanced Alternative Payment Model (APM) track.
For MIPS, CMS proposed to continue the 2017 transition year into the second performance year by postponing the cost performance category for another year. Although the federal agency is seeking feedback on whether to up the percentage value to 10 percent.
However, the rule would include the cost performance component for the 2019 performance year and cost performance would represent 30 percent of an eligible clinician’s MIPS composite score.
The MIPS quality category would also maintain its current weight. CMS proposes to continue scoring quality performance at 60 percent of the total MIPS composite score in 2018, rather than ramp down the value to 50 percent.
In addition, the Advancing Care Information category would see modifications in 2017. The final MACRA implementation rule requires eligible clinicians to use 2015 certified EHR technology. But the proposal would allow clinicians to still use 2014 or 2015 editions, with bonuses awarded to clinicians using only the 2015 edition.
The scoring and number of measures required for the fourth and final MIPS performance category, Improvement Activities, would not change under the proposed rule.
In terms of the Advanced APM track, CMS proposed to extend the revenue-based nominal risk amount standard for another two years. In 2017 and 2018, the total potential financial risk that must be under the APM is 8 percent of the average estimated Medicare Part A and B revenue or 3 percent of expected spending.
The proposed rule would lock in the 8 percent financial risk standard through the 2020 performance year.
To view all potential changes to the Quality Payment Program, stakeholders can find the full proposed rule here.