1. The QPP is alive and growing
There are significant changes in the new proposed rule relative to the 2018 plans laid out in the final rule governing the 2017 performance year, but the majority of the program is the same. Core program elements, such as performance categories and the structure of the program tracks, remains unchanged. Future program requirements look to be ramping as expected, as discussed below.
What does this mean for the small practice? MIPS has a definite and accelerating path, and now is a good time to get comfortable as the program ramps up the requirements over the next few years.
2. Cost category not included in your final score in 2018
CMS has proposed that cost will again account for 0% of the composite performance score in 2018 and not impact payments in 2020. While this is still not the final rule, it has momentum, and CMS is requesting feedback before the final rule is published. Based on this information the category weights would stay the same in 2018 as they did in 2017, with Quality counting for 60%, Advancing Care Information counting for 25%, and Improvement Activities counting for 15%.
What does this mean for the small practice? While not directly responsible for cost outcome, it is a good idea to monitor and understand the process and your data now, expect inclusion of Cost in your Composite Performance Score in 2019.
3. There will likely be more flexibility for small practices
CMS is proposing to increase the planned thresholds for low volume exclusions in 2018. The 2017 thresholds, where clinicians or groups with ≤$30,000 in Part B allowed charges or ≤100 Part B beneficiaries. CMS is proposing thresholds of ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries to qualify for exclusion in 2018.
What does this mean for the small practice? Low volume Medicare Part B practices may be excluded in 2018, to a larger degree than in 2017. All low volume practices should check their Medicare Part B metrics to determine their status.
4. Bonus points proposed
CMS has proposed adding additional bonus points to increase flexibility and reward clinicians and groups who have more difficulty scoring well in MIPS:
Proposed: Up to 10 percentage points available for performance improvement in the Quality category. This bonus will be based on the rate of improvement in the Quality category score between the 2017 performance year and the 2018 performance year.
Proposed: Additional bonus of up to 3 points available for eligible clinicians based on the medical complexity of patients they see. The assessment of medical complexity may be based on the average Hierarchical Conditions Category (HCC) risk score.
Proposed: A bonus of 5 points automatically awarded to any eligible clinician or group in a small practice with 15 or fewer clinicians.
What does this mean for the small practice? Small practices now have an added handicap that allows them to score bonus point to offset their small size, complex patient population and relative improvement in MIPS performance.
5. Virtual MIPS Groups are proposed
Virtual Groups will be comprised of eligible clinicians in solo practices or groups of 10 or fewer clinicians who elect to jointly participate in MIPS. By doing so small practices can offset low scores with other practices that may have high scores and improve both practices overall performance. The group as a whole reports the combined score which is attributed to each practice in the virtual group.
What does this mean for the small practice? Identifying your practice's areas of high and low MIPS performance and joining a Virtual Group to offset each other will lead to much better MIPS scores for all the practices in the Virtual Group. You will need to elect to participate in a Virtual group in 2018 prior to the start of the 2018 performance period.
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