Quality Payment Program Interim Final Rule

Glean Key Points on 2018 QPP From AAFP Executive Summary

November 15, 2017 01:58 pm News Staff

Family physicians likely are aware that on Nov. 2, CMS released an interim final rule(www.gpo.gov) with comment period covering the 2018 Quality Payment Program (QPP).  

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And just one week later, after carefully sorting through the 1,653-page document, the AAFP produced a four-page executive summary(4 page PDF) that highlights details for the second year of the QPP program that are most pertinent to family physicians.

Because the rule was issued with a comment period, the AAFP will have further opportunity to offer recommendations to CMS by Jan. 2. The AAFP's suggestions will, according to the summary, aim to "strengthen primary care for Medicare beneficiaries," as well as "support the ability for more physicians to participate in Advanced alternative payment models (AAPMs).

As background, it's important for physicians to understand that this interim final rule applies to the QPP 2018 performance period and will impact Medicare Part B payments in 2020. The two tracks available to physicians are the Merit-based Incentive Payment System (MIPS) and AAPMs.

Story Highlights
  • The AAFP has released a four-page executive summary of CMS' 1,653-page interim final rule on the 2018 Quality Payment Program.
  • The summary focuses on areas most likely to affect family physicians, including those caring for patients in small practice settings.
  • The Academy will continue to analyze the rule and looks forward to making further suggestions to CMS before the Jan. 2 commenting deadline.

The summary is chock-full of details physicians will want to read in their entirety; however, here are a few highlights to entice readers to invest the time.

MIPS Impact on Small Practices

The 2018 MIPS policies are of particular interest to the thousands of family physicians who care for their patients in small practice settings. One provision available to these FPs is the opportunity to participate in MIPS as a virtual group. 

But note: Physicians must elect this option before Dec. 31 to qualify for the 2018 performance period.

Furthermore, individual physicians and groups must exceed a revised low-volume threshold to qualify for virtual group participation. Increases to the low-volume threshold in 2018 likely will prevent more family physicians from participating.

"For the 2018 performance period, CMS will exclude individual MIPS-eligible clinicians or groups with less than $90,000 in Part B allowed charges OR fewer than 200 Part B beneficiaries," says the summary.

Other policies for 2018 that affect small practices include

  • the availability of five bonus points -- added to the final scores of practices with 15 or fewer eligible clinicians -- who submit data for at least one MIPS performance category,
  • an annual hardship exception for the Advancing Care Information category for practices with 15 or fewer eligible clinicians, and
  • the use of historical claims data rather than self-identification to make small practice determinations.

2018 MIPS Performance Period Details

A big change coming in 2018 is CMS' decision to implement a full-year performance period for both the MIPS quality and cost categories.

Also, CMS raised the performance threshold to 15 points for the 2018 performance period, compared to three points in 2017, and has left the exceptional performance threshold at 70 points.

Additional performance period policies include

How to Avoid a 4 Percent Penalty

The AAFP wants family physicians to know it's not too late to collect 2017 data and participate in the Merit-based Incentive Payment Program (MIPS).

In fact, submitting just one quality measure -- one time -- by Dec. 31 means a physician will avoid facing a 4 percent negative payment adjustment to Medicare Part B claims in 2019.

Plus, the more data a physician submits, the more opportunity he or she has to build a higher final MIPS score and thus increase the opportunity to receive a positive payment adjustment.

  • measurement of improvements in the quality and cost performance categories and the opportunity for eligible clinicians to earn bonus points for improvement,
  • availability of up to five bonus points for treatment of complex patients,
  • inclusion of Part B drugs costs in the MIPS payment adjustments, and
  • an automatic reweighting of the quality, advancing care information and improvement activity performance categories to zero percent of the final score for eligible clinicians impacted by Hurricanes Irma, Harvey or Maria, wildfires or other natural disasters.

The AAFP summary also delves into details regarding

  • 2018 MIPS performance categories,
  • major provisions for AAPMs and
  • key policies for MIPS APMs.

The AAFP continues to analyze this interim final rule and will provide additional educational materials to prepare family physicians for the 2018 performance period.

Related AAFP News Coverage
AAFP Urges Changes in 2018 Quality Payment Program Proposal
MIPS Performance Period, Measures, Cost Weighting Among Top Concerns


MACRA: The Medicare Access and CHIP Reauthorization Act

Additional Resource
CMS: Quality Payment Program Year 2: Final Rule Overview(www.cms.gov)