March 31, 2018 marks the close of the submission period for Medicare Access and CHIP Reauthorization
Act of 2015 (MACRA) Quality Payment
Program (QPP) data gathered during the
2017 performance period. Beginning on
January 1, 2019, the first payment adjust-
ments under QPP will occur. For physicians
and eligible clinicians who did
not submit 2017 performance data,
that will result in a negative 4%
As we know, MACRA includes
two tracks, the Merit-based Incentive
Payment System (MIPS) and the
Advanced Alternative Payment
Models (APM). CMS continued to
refine both MIPS and APM in the calendar
year (CY) 2018 final rule, which will affect
the QPP 2018 performance period and impact
clinician payments during 2020 and beyond.
Interestingly, the final rule projections reflect
that, of the 1,548,022 clinicians billing for
Medicare Part B services, approximately 40%
will be MIPS eligible, but only 11% and 15%
will participate through an APM.
A few noteworthy provisions of the CY
2018 final rule for MIPS include:
1. Both positive and negative payment
adjustments can be up to 5% for 2020.
2. An estimated 540,000 clinicians will be
excluded from MIPS by virtue of a considerable increase in the “low volume
threshold.” If a clinician or group has
less than $90,000 in Medicare Part B
allowed charges or sees fewer than 200
Part B beneficiaries, that clinician or
group is excluded.
3. Cost of care begins to factor into MIPS
as it represents 10% of the final score for
the 2020 payment year and increases to
30% during the 2021 payment year. On
the other hand, the quality performance
category decreases to 50% during the
2020 payment year and again to 30% for
the 2021 payment year.
4. Solo practitioners and groups of
fewer than 10 that would otherwise be excluded based on the low
volume threshold can group together
“virtually” irrespective of specialty and geographic location for
5. Bonus points are earned by QPP participants for treating complex patients,
demonstrating improvement in quality
or cost performance categories, and for
reporting performance data as a solo
practitioner or small group practice.
For 2018, QPP participants will need to
earn a minimum of 15 points to avoid
payment reductions in 2020. As a result,
participants will be required to report
multiple performance measures to
avoid a negative payment adjustment.
6. An automatic exemption from submitting quality, cost, and improvement
performance data was created for MIPS
participants affected by natural disasters or public health emergencies.
A good overview of the rule is available
at this link: http://go.cms.gov/2lJwse4
CMS Modifies MIPS in the
CY 2018 Final Rule
by Sharon Parsley, JD, MBA, CHC, CHRC
Sharon Parsley ( firstname.lastname@example.org) is President & Managing
Director of Quest Advisory Group, LLC, in Ocala, FL.
THE COMPLIANCE–QUALITY CONNECTION