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Special Report: June 20, 2017
CMS Proposes Additional Flexibility in 2018 Medicare Quality Payment Program
On June 20, the Centers for Medicare & Medicaid Services (CMS) published its proposed 2018 Quality Payment Program (QPP) established under the Medicare Access and CHIP Reauthorization Act (MACRA) that proposes reduced burdens and increased flexibility for physician quality reporting.
In order to reduce burden and make the program more flexible, the CMS specifically proposed:
- Providing a new Virtual Groups participation option
- Increasing the low-volume threshold so that more small practices and Eligible Clinicians (ECs) in rural and Health Professional Shortage Areas (HPSAs) are exempt from MIPS participation.
In 2018, most pathologists will need to take action to stop penalties from reducing future Medicare payments for their services mandated by MACRA. As is the case this year, nearly all pathologists will be required to participate in Medicare's Merit-based Incentive Payment System (MIPS).
A physician's performance in MIPS in 2017 and 2018 affects his or her Medicare payment in 2019 and 2020, respectively. The CAP is working to ensure pathologists can comply with MIPS, which is the default pathway under the QPP. The CAP will launch the Pathologists Quality Registry in October 2017, which can be a reporting option for the 2018 MIPS performance period. The MIPS program is estimated to have a $1.5 billion overall impact on the pathology specialty beginning in 2019.
In recent months, the CAP recommended several changes to the CMS regarding MIPS, to mitigate cuts and ensure pathologists can fairly participate in the program. These recommendations include:
- Hold pathologists harmless by using a median score for MIPS categories that non-patient facing eligible clinicians cannot report or participate in.
- Use Medicare enrollment records to define non-patient facing eligible clinicians.
- Extend the life of quality measures used by pathologists.
- Outline the Clinical Practice Improvement Activities (CPIA) and their impact on pathologists.
Register for June 28 Webinar on Proposed MACRA Rule
The CAP will report additional details about the proposed rule in future editions of STATLINE. The CAP will host a webinar on the proposed MACRA rule on June 28 at 1 PM ET, moderated by Patrick E. Godbey, MD, FCAP, Chair of the CAP Council on Government and Professional Affairs. Dr. Godbey will be joined by Jonathan L. Myles MD, FCAP, Chair, of the CAP Economic Affairs Committee and; Diana Cardona, MD, FCAP, Chair of the CAP Economic Affairs Measures & Performance Assessment Subcommittee, who will discuss how these proposed Medicare pay changes under MACRA will affect pathologists in 2018.
MIPS combines the Medicare quality payment programs—the Physician Quality Reporting System (PQRS), Electronic Health Record Meaningful Use (EHR MU), the Value-Based Modifier (VBM), and Clinical Practice Improvement Activities (CPIA). The penalties established under the current PQRS, EHR MU, and VBM programs will sunset in 2018.
Scoring or reweighting categories that non-patient facing eligible clinicians (ECs) cannot participate
The CAP advocated to automatically re-weight advancing care activities scores for non-patient facing ECs. The CMS is currently soliciting comments on an alternative proposal to distribute the weight of the ACI category to both the Quality and CPIA categories instead of just to the Quality category. This would weigh the Quality category at 75% and IA at 25% for non-patient facing ECs. The ACI scoring allows everyone to succeed or at minimum getting 50% of the score, giving those with a score in ACI an advantage over those with a greater percentage of their total score under quality. Re-distributing the weight to two categories instead of just one would give pathologists the opportunity to score more fairly in MIPS.
Defining Virtual Groups and Non-Patient Facing Eligible Clinicians (ECs)
The CMS did not change the definition of non-patient facing eligible clinicians (ECs) in this proposed rule, but added a new type of practitioner group, a Virtual Group, which is another way clinicians can elect to participate in MIPS. Virtual Groups are either a solo eligible clinician or a group of 10 or less eligible clinicians, who come together "virtually" with at least 1 other such solo eligible clinician or a group to participate in MIPS for a performance period of a year. The non-patient facing Eligible EC definition remains the same as an individual EC who bills 100 or fewer patient-facing encounters or a group with more than 75% of the National Provider Identifier (NPIs) billing under the group’s Tax Identification Number (TIN) that meet the definition of a non-patient facing EC.
Increasing the Low-Volume Threshold
The CMS would like to increase the low-volume threshold so that more small practices and eligible clinicians in rural and Health Professional Shortage Areas (HPSAs) are exempt from MIPS participation. The new proposed low-volume threshold would exclude ECs with less than $90,000 in Medicare Part B charges, or less than 200 Medicare Part B patients from MIPS .
Topped Out Measures
The CMS has proposed a 3-year timeline for a process to identify topped out measures that should be removed from the program. After a measure has been identified as topped out for three consecutive years, the CMS may propose to remove the measure through comment and rulemaking for the 4th year. This proposal provides a path toward removing topped out measures over time, and will apply to the MIPS quality measures. Qualified Clinical Data Registry (QCDR) measures that consistently are identified as topped out according to the same timeline would not be approved for use in year 4 during the QCDR self-nomination review process.
Clarifying and Increasing the Number of Clinical Practice Improvement Activities (CPIA)
The CMS has added 20 new improvement activities in the proposed rule in addition to the previously finalized ones. STATLINE will report on these new improvement activities and how they will impact pathologists in the coming weeks. The CAP will continue to advocate for the inclusion of activities applicable to pathologists.
Alternative Payment Models
The CMS predicts that more eligible clinicians (approximately 180,000–245,000 for payment year 2020) will become Qualifying Participants in Advanced Alternative Payment Models and that more models will be available in 2018. The CMS seeks comments on whether to broaden the Physician Focused Payment Models (PFPM) definition to include Medicaid and CHIP arrangements even if Medicare is not a payer. The CMS is also seeking comments on the current PFPM criteria and stakeholder needs in developing PFPM proposals.