Last week, CMS issued a Proposed Rule suggesting changes for Year 2 of the Quality Payment Program ("QPP"), established under the Medicare Access and CHIP Reauthorization Act of 2015. The changes are aimed at reducing administrative and financial burdens of the QPP on physician practices, particularly small independent practices and practices serving rural communities. Per CMS, the Proposed Rule "continues the slow ramp-up of the Quality Payment Program by establishing special policies for Program Year 2 aimed at encouraging successful participation in the program while reducing burden, reducing the number of clinicians required to participate, and preparing clinicians for the CY 2019 performance period."

Let's take a look at a few of the most significant changes proposed in the Rule:

Increase to Low-Volume Threshold

This is one of the biggest changes from the 2017 Final Rule. During the 2017 transition year, physicians billing more than $30,000 per year to Medicare Part B and seeing more than 100 Medicare beneficiaries were required to participate in the QPP or face a 4% reduction to their Medicare reimbursement in 2019.  The Proposed Rule raises this threshold for 2018 to physicians billing more than $90,000 per year to Medicare Part B and seeing more than 200 Medicare beneficiaries. This increased threshold is expected to result in approximately 134,000 clinicians being deemed exempt from participation in the QPP for 2018.

MIPS reporting via "Virtual Groups"

The Proposed Rule allows solo practitioners and those in groups of 10 or fewer practitioners to come together in "virtual groups" for purposes of reporting their performance measures under MIPS. In general, the same policies that apply to a practice reporting as a group (rather than as individual clinicians) under MIPS would apply to these virtual groups. The idea here is to allow solo practitioners and small practices to aggregate their Medicare billings for purposes of meeting the volume threshold for participation in MIPS and to facilitate pooling of resources such as use of a Qualified Registry or EHR to reduce the cost of participation.

Use of Certified Electronic Health Record Technology

The 2017 Final Rule allowed use of 2014 Edition CEHRT for scoring in the Advancing Care Information performance category, but required use of 2015 Edition CEHRT by the 2018 performance year. The Proposed Rule allows clinicians to continue to use 2014 Edition CEHRT in 2018, but it awards bonus points in the Advancing Care Information category for use of the 2015 Edition CEHRT. This will allow small practices more time to transition to new EHR technology.

Bonus Points for Complex Patients and Small Practices

The new Proposed Rule would adjust a clinician or practice's overall performance score by adding up to three points for those whose patient population consists largely of medically complex patients. The rule also proposes awarding five points to the final score of practices consisting of 15 or fewer clinicians, IF the practice submits data in at least one performance category in an applicable reporting period. This proposal could give small practices and those serving complex patients a leg up in the final scoring that will determine reimbursement for the payment year.

Cost as a Component of Performance Score

The 2017 Final Rule assigned the Cost category a "zero percent" weighting towards calculation of the overall Performance Score in 2017, increasing weighting to 10% in 2018. The Proposed Rule keeps Cost weighting at zero percent for the 2018 performance year. 

For more information, check out our MACRA series of articles and videos. To learn how your practice can take practical steps right now to position itself for optimal reimbursement under MIPS, visit

MACRA for Physicians, Part 1

MACRA for Physicians, Part 2

MACRA for Physicians, Part 3

Video: MACRA and the Trump Administration

And don't hesitate to Contact Us if you need help preparing your practice for MACRA!

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