What’s happening for QPP Year 2
Consistent with the Trump administration’s policy of reducing regulatory burdens across the government, CMS announced earlier this year that for QPP Year 2, steps are being made to reduce paperwork burdens on clinicians and the MIPS reporting change requested in the medical groups’ letter would seem to be consistent with that objective.
According to a CMS fact sheet, those changes, in what CMS is calling its “Patients Over Paperwork” program, include excluding individual MIPS-eligible clinicians or groups with $90,000 or less in Part B allowed charges or 200 or fewer Part B beneficiaries; addressing extreme and uncontrollable circumstances, such as hurricanes and other natural disasters, for both the transition year and the 2018 MIPS performance period; including virtual groups as a new participation option; and making it easier for clinicians to qualify for incentive payments by participating in Advanced APMs that begin or end in the middle of the year.
In addition, CMS said new policies have been adopted to further reduce clinicians’ burden and provide more ways for participation. While keeping many transition-year policies, CMS is making these additional changes:
- raising the performance threshold to 15 points in Year 2 (from three points in the transition year)
- allowing the use of 2014 edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2, and providing a bonus for using only 2015 CEHRT
- giving up to five bonus points on the final score for treatment of complex patients
- automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the final score for clinicians impacted by Hurricanes Irma, Harvey, and Maria and other natural disasters
- adding five bonus points to the final scores of small practices
- giving solo practitioners and small practices the choice to form or join a virtual group to participate with other practices
- continuing to award small practices three points for measures in the Quality performance category that don’t meet data completeness requirements.
Overall, CMS said the policy changes mean that:
• Clinicians in affected areas that do not submit data will not have a negative adjustment.
• Clinicians that do submit data will be scored on their submitted data. This allows them to be rewarded for their performance in MIPS. Because MIPS is a composite, clinicians have to submit data on two or more performance categories to get a positive payment adjustment.
• The policy applies to individuals (not group submissions), but all individuals in the affected area will be protected for the 2017 MIPS performance period.
• If a MIPS-eligible clinician who is eligible for reweighting due to extreme and uncontrollable circumstances, but still chooses to report (as an individual or group), they will be scored on that performance category based on their results.
• This policy does not apply to alternative payment models.
In addition, CMS said it is taking steps to increase participation in Advanced APMs, which may allow them to qualify for incentive payments.
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