On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) issued the 2018 final rule for the Quality Payment Program (QPP) established under the Medicare Access and CHIP Reauthorization Act of 2015(MACRA). The program’s first year was 2017, which saw updates softening key parameters that slowed full implementation due to complexity and physicians’ ability to adopt—specifically small and rural practices.
The CMS continues its incremental implementation of MACRA in the program’s second year. Many key updates in the proposed 2018 rule carried over to the final rule, but there were a few unanticipated changes. BKD continues to analyze the final rule to find insights and potential implications. Below is a current primer of the 2018 final rule’s key updates:
Effect for Providers
Given the final rule updates, it appears the CMS will continue to focus on reducing the reporting burden on some providers and provide flexibility on how providers can participate. The CMS has maintained a number of those flexibilities from the first year to help clinicians better prepare for the program’s third year. Although the CMS has finalized updates expected to ease clinicians into the third year, it also made updates that will require providers to renew their concentration on quality and cost performance in 2018. There are three areas of the 2018 final rule where providers and organizations should consider focusing:
- Quality – For performance year two, the CMS is expanding the quality reporting period from 90 days in 2017 to a full calendar year for 2018. In addition, clinicians will be scored on their quality improvement and might be eligible for up to 10 percentage points based on improvement. Therefore, it’s important for clinicians and organizations to determine their quality reporting in year two, because it’s likely to be a considerable part of successful performance.
- Cost – The CMS will begin to assess cost performance in 2018, which is a change from the proposed rule. The cost category will be weighted to 10 percent of the MIPS final score. The cost category is required to be weighted to 30 percent in the program’s third year. Because of this statutory requirement, the CMS believes a gradual implementation of the cost category will allow clinicians to better prepare for year three. The cost performance category likely will be a key element in being a high performer in year two; therefore, clinicians and organizations should use the cost feedback from the 2017 performance period to inform their cost performance strategies in 2018.
- Complex patient bonus – The complex patient bonus is a new bonus for the program’s second year. This is one way the CMS provides support to clinicians. For this bonus, the CMS will assess a clinician’s HCC risk scoring across its patient population and award up to five bonus points for treating complex patients. To be accurately assessed for this bonus, it’s vital for providers to understand best practices for documenting HCCs for their beneficiary population.
Next Steps for Organizations
- Conduct a holistic review of your organization’s quality and cost measures under the VBP program through Quality and Resource Use Reports. Since the CMS has adopted the facility-based measures reporting option, organizations now have an opportunity to align and focus their performance strategies across value-based payment programs to enhance performance and reduce reporting burden.
- Assess opportunities to form virtual groups or partnerships with solo or small practices. With the addition of virtual groups in 2018, solo and small practices will increasingly look to form groups or partner with other organizations to improve performance under MIPS.
- Identify and refine your organization’s value-based reimbursement strategy. Risk-based arrangements are becoming an increasingly popular tactic for track selection under the QPP. In the proposed rule, the CMS has estimated that Advanced APM participation will grow by 104 percent between performance year 2017 and 2018. With more clinicians potentially excluded from MIPS reporting and the uptick in Advanced APM participation, the MIPS track is becoming more competitive. Organizations should begin to evaluate current capabilities to manage payment risk, assess timing and feasibility of potentially entering into risk-based reimbursement strategies and evaluate how it will affect their QPP strategy.
Find additional resources and tools for the QPP at the CMS Quality Payment Program resource library. The CMS developed a MIPS lookup tool for clinicians to verify eligibility and identify if the clinician or group qualifies for special status, which may result in bonus points or preferential scoring. For more resources related to MACRA, MIPS, Comprehensive Primary Care Plus and other CMS Innovation initiatives, visit BKD’s Payment Reform Resource Center.