CMS Finalizes Quality Payment Program Rule for Year 2018

Mario Fucinari, DC, CCSP, APMP, MCS-P, CPCO

On November 2nd, the Centers for Medicare & Medicaid Services (CMS) issued the final rule with comment for the second year of the Quality Payment Program (calendar year 2018), as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) as well as an interim final rule with comment.

CMS wants to ensure that the program consists of meaningful measurement while minimizing burden, improving coordination of care, and supporting a pathway to participation in Advanced Alternative Payment Models (APMs).

Year 2 Final Rule Highlights

The policies for Year 2 of the Quality Payment Program include some significant changes affecting chiropractors.

• The final rule decreased the number of doctors and clinicians required to participate 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.
• 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 application (note that Cost has a 0% weight in the transition year) if they were affected by Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period.

For those eligible in the program:

• Weighting the MIPS Cost performance category to 10% of your 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 your 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.
• 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.

For further information, please see the government’s website information at www.qpp.cms.gov.

Dr.  Fucinari is a Certified Medical Compliance Specialist (MCS-P) and a Certified Professional Compliance Officer (CPCO).  He is a member of the Medicare Carrier Advisory Committee.  He is on the speaker’s bureau for NCMIC, Foot Levelers, and ChiroHealthUSA.  He is a frequent speaker at chiropractic colleges and state associations.  To schedule Dr. Fucinari for your event or for further information and available resources, Dr. Mario Fucinari can be contacted at Doc@Askmario.com or through www.Askmario.com.