CMS Publishes Final Rule for 2018

For the Quality Payment Program

On November Second, Centers for Medicare and Medicaid (CMS) published their final ruling for the Quality Payment Program (QPP) under MACRA for the year 2018, outlining changes that have been implemented to make participation more bearable.  The ruling achieves this through simplification of certain aspects of the program, and by reducing the burdens it has placed on clinicians.  The changes to “Year 2” of the QPP aim to transform 2018 into a second transitionary year, incrementally preparing clinicians for full participation in the year 2019.

The Final Rule from CMS weighs in at 1,658 pages.  That’s a lot of reading to do in the little spare time that most clinicians have to implement the changes necessary to participate the QPP and MIPS in 2018, so we’ve broken it down and highlighted the major changes.

Types of changes:

Bonus Points:

CMS has reduced portions of participation in the Quality Payment Program from mandatory, to incentivized, by offering bonus points to clinicians who achieve them in the year 2018.  This enables CMS to get as many clinicians that can make these changes to do so, while not penalizing those who are not yet ready to make the changes.

These include:

  • Allowing practices to continue to utilize 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) for the Advancing Care Information performance category, and giving a bonus to practices who only utilize those with 2015 CEHRT.
  • Awarding practices who treat complex patients up to 5 bonus points on their MIPS final score.
  • Small practices can now achieve up to 5 bonus points to their MIPS final scores.

Reduction or Change of Requirements:
CMS has recognized that there are parts of participation in the Quality Payment Program that, when combined with the other parts of the MACRA legislation, may become a bit of a burden for various clinicians and practices.  In this final ruling, they have taken aim at these burdens and either reduced the requirements, or made changes making them more flexible.

These include:

  • Decreasing the number of doctors and clinicians required to participate and excluding individual MIPS eligible clinicians or groups with ≤$90,000 in Part B allowed charges or ≤200 Medicare Part B beneficiaries.
  • CMS raised the MIPS performance threshold from 3 to 15 points in Year 2.
  • CMS changed the Weight of MIPS Cost performance category to 10% of your total MIPS final score, and the Quality performance category to 50%.
  • CMS will automatically change the weighting of Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the MIPS final score, when clinicians are impacted by Hurricanes Irma, Harvey and Maria and other natural disasters.


Additions to the Rule:

As a third method of making the Quality Payment Program more flexible and less of a burden, CMS has added the following as part of their ruling.

These include:

  • Creating Virtual Groups as a participation option for MIPS.
  • CMS is providing more detail on how eligible clinicians participating in certain APMs (known as MIPS APMs) will be assessed under the APM scoring standard.
  • Creating additional flexibilities and pathways to allow practices and clinicians to be successful under the All Payer Combination Option. CM is to publish these in the beginning of 2019.
  • Issuing an entire interim final rule with comment for situations where extreme and uncontrollable circumstances that can automatically exempt clinicians from these categories in the transition year without submitting a hardship exception application (note that Cost has a 0% weight in the transition year) if their practice has been affected by Hurricanes Harvey, Irma, and Maria.

To view the full CMS Fact Sheet click here.

And starting on November 16th, you can down the full rule here.