MIPS category percentages shift
Beginning in 2018 the cost category—based on claims data—becomes 10% of eligible physicians’ final MIPS score. This represents a major change from the proposed rule, which kept it at 0% next year. CMS will calculate cost through Medicare Spending per Beneficiary (MSPB) and total per capita cost measures for 2018—carryovers from the Value Modifier program.
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The quality performance category shifts from 60% of a physician’s score this year to 50% in 2018. In 2019, quality drops to 30% of a clinician’s overall score. The advancing care information category (25%) and clinical improvement activities (15%) categories retain their percentages next year as well as the 90-day reporting period.
However, reporting for cost and quality categories will encompass the entire calendar year and CMS has noted that will continue in 2019 (affecting 2021 reimbursement). This will likely be opposed by physician groups because of the length of the reporting period.
New clinical improvement activities
In addition to changing 27 previously adopted clinical improvement activities, CMS is finalizing 21 new activities for 2018. These include achieving health equity via participation in clinical trials, research alliances or community-based research, providing education opportunities for new clinicians and sharing EHR systems between primary care and behavioral health practices.
MIPS performance threshold raised
The scoring system performance threshold increases to 15 points in 2018 to avoid a penalty, up from three points this year. This means eligible clinicians will need to report data to qualify for a minimum of those 15 points from the various MIPS categories to receive a neutral payment adjustment (neither a penalty nor a bonus). An additional performance threshold remains at 70 points for exceptional performance.
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For the current year, payments will be adjusted up or down 4%. This rises to +/- 5% on 2020 payments (based on 2018 data).
No rush to switch EHRs
Originally, CMS wanted Medicare-eligible physicians to use 2015 Certified Electronic Health Record (EHR) technology. Seen as a burden for practices, especially smaller ones, CMS will allow use of 2014 Edition EHRs and instead provide a bonus to practices who have 2015 Edition systems.
Recognition of complex patients
There has been a lot of discussion since the Quality Payment Program was unveiled regarding how complex patients could drag down quality metric reporting as physicians struggle for adherence and/or care improvement. In 2018, CMS will award five bonus points in the MIPS program for treatment of such patients. This is seen as a move to appease critics who urged CMS not to water down standards and maintain their uniformity, while acknowledging adherence struggles for some patients.