The Centers for Medicare & Medicaid (CMS) recently issued the final rule will comment period for the second year of the Quality Payment Program. While Year 2 is said to be transitional, CMS has said they are making some minor changes and also preparing clinicians for a more robust program in Year 3.
As part of their announcement, CMS provided the following Year 2 Final Rule Highlights:
- Weighting the MIPS Cost performance category to 10% of the eligible clinician's total MIPS final score, and the Quality performance category to 50%.
- Raising the MIPS performance threshold to 15 points in Year 2 (from 3 points in the transition year).
- Allowing the use of 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2 for the Advancing Care Information performance category, and giving a bonus for using only 2015 CEHRT.
- Awarding up to 5 bonus points on the MIPS final score for treatment of complex patients.
- Automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the MIPS final score for clinicians impacted by Hurricanes Irma, Harvey and Maria and other natural disasters.
- Adding 5 bonus points to the MIPS final scores of small practices.
- Adding Virtual Groups as a participation option for MIPS.
- Issuing an interim final rule with comment for extreme and uncontrollable circumstances where clinicians can be automatically exempt from these categories in the transition year without submitting a hardship exception if they were have been affected by Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period.
- Decreasing the number of doctors and clinicians required to participate as a way to provide further flexibility by excluding individual MIPS eligible clinicians or groups with $90,000 in Part B allowed charges or 200 Medicare Part B beneficiaries.
- Providing more detail on how eligible clinicians participating in selected APMs (known as MIPS APMs) will be assessed under the APM scoring standard.
- Creating additional flexibilities and pathways to allow clinicians to be successful under the All Payer Combination Option. This option will be available beginning in performance year 2019.
The provisions of the final rule with comment period and interim rule with commend period will be effective on January 1, 2018; however, comments may be submitted no later than January 2, 2018.
Healthcare Compliance Pros will be analyzing the updates to the Quality Payment Program and providing tips and recommendations to help practices successfully participate in MIPS Year 2.
If you are participating in MIPS this year the transition year your 2017 MIPS performance data should be submitted January 2 through March 31, 2018. It's important to note that as long as you submit something, even data you collect as of December 31st, you will be able to avoid a negative payment adjustment. However, the more data you submit in a timely manner, in the data submission window the better the odds of receiving a positive payment adjustment in 2019.
If you have any questions about MIPS participation contact us today by phone: 855-427 0427 or by email: [email protected].