The AAFP has posted for family physicians' review a two-page executive summary(2 page PDF) that highlights some key provisions of CMS' recently proposed updates to the 2018 Quality Payment Program (QPP).
Annual proposed updates are required by law, and the lengthy proposed rule was made public(s3.amazonaws.com) on June 20; the regulation will be published in the Federal Register on June 30.
The AAFP's summary comes in advance of what will be a far more detailed comment letter that will land on the desk of CMS Administrator Seema Verma, M.P.H., before the Aug. 21 comment deadline.
New Estimates for Program Participants
Per the AAFP summary, CMS projects than an additional 134,000 physicians and other eligible clinicians or groups will be exempt from the Merit-based Incentive Payment System (MIPS) -- adding significantly to the nearly 700,000 that were already able to skate under the low-volume threshold established in the 2017 QPP final rule. The agency estimates that nearly half of the additional excluded physicians will be from small practices.
- The AAFP has created a two-page executive summary of the lengthy proposed rule outlining updates to the 2018 Quality Payment Program; a comprehensive comment letter will come in August.
- CMS has updated estimates for the number of physicians who are excluded from participating in the Merit-based Incentive Payment System and for the number of physicians who could earn an incentive by participating in an Advanced Alternative Payment Model.
- CMS took AAFP concerns to heart and, among other changes, revised sections related to virtual group participation and appropriate use criteria.
Currently, excluded physicians must have less than $30,000 in Medicare Part B allowed charges or fewer than 100 Medicare Part B beneficiaries. For 2018, CMS has proposed excluding from MIPS eligibility clinicians or groups that bill less than $90,000 in Part B allowed charges or who have fewer than 200 Part B beneficiaries.
Regarding the Advanced Alternative Payment Model (Advanced APM) payment track, in the proposed rule, CMS increased its estimate of eligible health professionals who would become qualifying Advanced APM participants in the 2020 payment year to between 180,000 and 245,000.
Compare that to previous CMS estimates that 70,000 to 120,000 eligible clinicians would earn incentive payments in 2019 for participating in an Advanced APM in the 2017 performance year.
AAFP Makes an Impact
It is clear from the Academy's summary that CMS has indeed proposed adjustments in some areas where the AAFP has repeatedly pushed hard for changes.
For instance, CMS finally offered a virtual group participation option for practices with 10 or fewer physicians.
According to the summary, on multiple occasions -- both in private meetings with CMS and in letters to the agency -- "the AAFP identified virtual group participation as critical to the ability of practices to participate successfully in MIPS."
It's important to note that "virtual groups that choose this participation option will need to make an election prior to the 2018 performance period," says the summary.
In addition, proposed changes to the agency's appropriate use criteria (AUC) program(www.cms.gov) suggest that CMS took some of the AAFP's previous concerns and recommendations to heart.
Furthermore, the AAFP noted that CMS has proposed adding a "new, optional improvement activity" when a physician attests to using AUC via a qualified clinical decision support mechanism for all advanced diagnostic imaging services ordered.
That's a positive move by CMS considering the AAFP's oft-stated concerns about the "disproportionate burden" family physicians would bear if they had to comply with appropriate use requirements.
Additional Highlights for FPs
The AAFP summary highlights a number of additional CMS proposals for the 2018 QPP, including
- modifying the agency's definition of a certified patient-centered medical home,
- allowing the continued use of 2014 edition certified electronic health record technology while encouraging the use of 2015 edition technology,
- accepting accredited CME as an improvement activity,
- adding bonus points in the scoring methodology when physicians care for complex patients,
- adding hardship exceptions for the advancing care information performance category for practices with 15 or fewer clinicians, and
- adding bonus points to the final score of physicians in small practices for submitting data on at least one performance category.
Read the summary for more detailed information about CMS' proposals related to Advanced APMs, and watch for the full comment letter to come in August.
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