Complex patients will be determined by a combination of Hierarchical Condition Categories and the number of dually eligible patients a practice treats.
Relief for practices and patients affected by hurricanes
On the heels of offering relief to citizens whose enrollment in Medicare Part A or Part B for the coming year is affected by recovering from recent natural disasters, CMS is also offering relief to physicians. Evaluated on a case-by-case basis via hardship application for providers in areas declared an emergency or major disaster by the Federal Emergency Management Agency, CMS will count only the cost category for MIPS-eligible physicians. This affects physicians in the areas impacted by hurricanes Irma, Harvey, Maria and other recent natural disasters for both the current reporting year as well as 2018.
MIPS-eligible clinicians who are able to report data for 2017 will be rewarded for their performance, but those who cannot report due to the natural disaster will not face a penalty in 2019. In addition to releasing the final rule for 2018, CMS issued an interim final rule for 2017 to address “automatic extreme and uncontrollable circumstance policy” for this year in the wake of all the natural disasters.
Furthermore, if a MIPS-eligible clinician’s certified EHR is unavailable in 2018 due to “extreme and uncontrollable circumstances” (such as a hurricane, natural disaster or public health emergency), practices can submit a hardship exemption application by December 31, 2017, for consideration. If deemed a hardship, the clinician’s advancing care information performance category weight would be readjusted.
Bonus for small practices
Small practices will get five bonus points on their MIPS final scores. These practices are defined as having 15 or fewer eligible clinicians. The bonus is awarded as long as the eligible physician (or group) submits data for at least one performance category.
In addition, as it is doing this year, CMS will continue to award small practices three points for measures in the quality performance category that don’t meet data completeness requirements for an entire patient panel.
HOT TOPIC: Here's how we can fix healthcare
CMS also announced it will allow MIPS-eligible physicians to continue to apply for hardship exemptions in the advancing care information performance category regarding their EHR systems. This can include insufficient internet connectivity and lack of control over availability of certified EHRs.
Creation of virtual groups
Initially unveiled in the 2018 proposed rule in June, CMS will permit creation of “virtual groups” for solo practitioners and groups of 10 or fewer eligible clinicians. These professionals can partner with at least one other group to report MIPS quality metrics, regardless of location or specialty.
CMS has developed a Virtual Groups toolkit to assist eligible physicians in understanding the ins and outs of this new structure.
Easier Alternative Payment Model (APM) participation
Seeking greater participation in APMs, CMS is loosening some requirements for participation in 2018. This includes exempting initial Comprehensive Primary Care Plus participants from the 50-clinician limit for organizations that can earn incentive payments via medical home models. CMS is also easing the requirement for medical home models to the minimum required amount of financial risk assumed by practices.
CMS anticipates between 185,000 and 250,000 clinicians will participate in APMs in 2018, up from 70,000 to 120,000 this year.