With the new year less than two months away, practices are analyzing the latest set of guidelines for Medicare’s Quality Payment Program (QPP) that take effect in 2018.
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In the final 2018 rules for the Medicare Access and CHIP Reauthorization Act, the minimum-volume threshold has been increased, which means more small practices and solo providers are exempt from the Merit-based Incentive Payment System of the QPP. The new exemption level is 200 patients or fewer, or $90,000 or less in Medicare Part B charges per year, up from 100 and $30,000 in the proposed rule.
But according to Tony Panjamapirom, senior consultant with the Advisory Board, this exemption may not last forever. “Providers still need to be careful, even if exempt,” says Panjamapirom. “They still should pay attention to MIPS policy, and better yet, participate voluntarily so you can start tracking their performance. In one way or another, I’m pretty sure small practices will come back into the scene in future years. Do not sit back and relax.”
Other highlights of the 2018 final rule include:
· Allowing physicians impacted by extreme and uncontrollable circumstances, such as the recent hurricanes, to get relief from reporting requirements.
· An option for physicians in small practices to combine into virtual groups for reporting purposes.
· Cost is now 10% of the final MIPS score, up from the proposed 0%.
· Quality and cost categories will require full-year reporting.
· 2014 Certified Electronic Health Record (EHR) technology is allowed, but those with 2015 Certified EHRs get bonus points.
· Caring for complex patients nets five bonus points.
· Small practices—those with 15 physicians or fewer—receive five bonus points in MIPS.
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Reaction to these changes in the final rule has been mixed. Most see some positive improvement, but agree there is more work that needs to be done. For example, the American College of Physicians (ACP) applauded the relief for doctors impacted by hurricanes and other disasters, and also the increase in bonus points within MIPS for treating medically complex patients and the virtual groups option.