On Thursday, November 2, 2018, the Centers for Medicare and Medicaid Services (CMS) issued its final rule
for Year 2 of the Quality Payment Program (QPP), established under MACRA. Several of AANEM’s suggestions were adopted in the final rule. Of key importance is that CMS is, essentially, providing for another transition year. However, eligible clinicians will be required to participate to a greater extent in 2018 to avoid a negative payment adjustment. For information about the rule in effect for the current year, visit AANEM’s MACRA webpage: https://www.aanem.org/Practice/Medicare/MACRA
Based on a cursory review of the rule, it appears that CMS listened to extensive feedback provided by various medical associations and groups, including the AANEM, and made several changes to the QPP based on physician input. Some of the biggest changes, noted below, involve additional accommodations for small practices (defined as practices with 15 or fewer eligible clinicians):
The low volume threshold exemption will increase to $90,000 or less in Medicare Part B allowed charges OR 200 or fewer Medicare Part B patients (previously was $30,000 or 100 patients);
5 points will be automatically added to the final MIPS score for small practices;
A hardship exemption will be implemented for small practices for the Advancing Care Information (the EHR requirement – formerly Meaningful Use) category; and
“Virtual groups” will be created to allow solo or small practices to participate in MIPS together.
There are also several changes to the requirements of each of the four categories of MIPS (Quality, Advancing Care Information, Improvement Activities, and Cost) which should help ease the burden on eligible clinicians. For example, clinicians will be allowed to continue to use 2014 edition certified EHRs (CEHRT). Another change, which differed from what was proposed in June 2018, is that the Cost category will now count for 10% of the final MIPS score in 2018. In the proposed rule released in June, CMS had suggested continuing to weight the Cost category to zero, as was done in 2017. Finally, CMS also added leniency for physicians and practices affected by Hurricanes Harvey, Irma, and Maria for 2017; and, additionally, issued an interim
rule that would automatically exempt these clinicians from MIPS reporting requirements.
The policy staff at AANEM is diligently reviewing all 1,653 pages of the proposed rule to determine how the changes will affect AANEM members. AANEM will continue to keep its members informed of key provisions and will create new tools to help AANEM members navigate the QPP in 2018.
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