Nine things to know about the final 2018 MACRA rule

By Moshe Starkman, nThrive Senior Value-Based Reimbursement Consultant | Posted: 11/09/2017

On Nov. 2, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2018 revisions to the Quality Payment Program (QPP). While the 2018 final rule holds no big surprises, closely following the payment policies, rates and quality provisions reflected in the proposed rule released in June, there are nine important takeaways providers should be aware of. 

Transition continues

As with the QPP Year 1, CMS will continue with its “transition” theme into Year 2. Said CMS Administrator, Seema Verma, “During my visits with clinicians across the country, I’ve heard many concerns about the impact burdensome regulations have on their ability to care for patients.”

To ease the regulatory burden in QPP Year 2, CMS will continue to improve and build upon the momentum of year one by providing:

  • Physician assistance – free, hands-on Technical Assistance (TA) to help provider groups participate in QPP
  • Flexibility to assist in physician burden reduction to progress ramp up to CY 3
  • New participation incentives

With just two months to prepare for the January 1, 2018 start, it’s imperative that physicians take note of the impending QPP changes.

Here are nine important takeaways from QPP year 2:

1. Increased participation threshold

Approximately 63 percent of all Medicare clinicians will be exempt from MIPS in 2018. In accordance with the proposed rule, physicians or groups eligible with $90,000 or less in Medicare Part B allowed charges (up from $30,000 or less in 2017) or 200 or fewer Part B beneficiaries (up from 100 or less in 2017) will be excluded from MIPS reporting in 2018. It is estimated that 134,000 clinicians will be added to the exemption list, raising the total to 926,000 ineligible MIPS clinicians.

2. MIPS performance category changes

  • Quality: The composite score weight decreases from 60 percent to 50 percent of a physician’s score in 2018. A minimum 12-month performance period for is required.
  • Cost: The composite score weight Increases from 0 percent to 10 percent weight in 2018. A minimum 12-month performance period for is required.
  • Clinical improvement activities: The composite score weight remains at 15 percent weight in 2018. A minimum 90-day performance period for clinical improvement activities is required. CMS will also be adding 21 new activities to the 2018 lineup, while modifying 27 existing activities.
  • Advancing care information (ACI): The composite score weight remains at 25 percent in 2018. A minimum 90-day performance period for advancing care information is required.

In 2018, the MIPS performance scoring structure increases by 15 points, which raises the payment adjustment to +/- five percent for the 2020 payments.

3. Reporting method flexibility

Individual MIPS-eligible clinicians and groups won't be able to submit measures and activities through multiple submission mechanisms in 2018 despite earlier rumors.

4. Additional participation options

MIPS-eligible clinicians can participate as individuals, groups or as a virtual group in 2018. Solo practitioners and groups with 10 or fewer eligible clinicians can participate in MIPS by joining together as a virtual group. CMS believes this new reporting option will be especially positive for small practices. There are no restrictions on groups based on size, geography or specialty, however, it’s important to note the election period ends December 1, 2017.

5. Small practice opt-out options

In 2018, practices with 15 or fewer clinicians can apply for a new hardship exception to shift the ACI scoring weight to 25 percent to the quality category, reweighting the ACI category to zero percent.

6. EHR requirements tweaked for MIPS not APM

In 2018, MIPS-eligible clinicians can use either 2014 or 2015 Edition certified EHRs (CEHRT) for the MIPS ACI category. However, a 10 percent ACI bonus will be awarded to those who use the 2015 Edition. There is added flexibility as the 90-day reporting period will stay intact, which allow providers to make the switch to the 2015 Edition by October 1, 2018 instead of January 1, 2018.

Unfortunately, APM participants did not get the same reprieve as MIPS eligible-clinicians. In 2018, APM participants are required to use 2015 CEHRT for a full year beginning January 1, 2018.

7. Bonus points awarded for complex patient care

MIPS-eligible clinicians will be awarded five bonus points for the treatment of complex-care patients based on the Hierarchical Condition Categories definition and the number of complex patients treated by a practice.

8. Relief for extreme and uncontrollable circumstances 

CMS is offering clinicians, who are providing care in areas deemed an emergency or disaster area by the Federal Emergency Management Agency, the opportunity to submit a hardship application that will be considered for reweighting of the ACI performance category. The application is due by December 31, 2017. 

9. Small practice bonus

Small practices with 15 or fewer eligible clinicians will get five bonus points added to their MIPS composite score if the eligible physician or group submits data for at least one performance category in 2018. For clinicians who don’t meet the data completion requirements for an entire patient panel, CMS will continue to award three points for measures in the quality performance category. Clinicians can apply for ACI performance category hardship exemptions regarding their EHR systems as done in 2017.

What Next?

While the QPP Year 2 brings with it a continued flexibility and higher participant threshold, which is a welcome respite to many, others fear it in turn muffles the call to action toward value-based care. The questions many are asking include, “Will clinicians take advantage of another ‘transition’ year and be ready for the impact of 2019 full-throttle? Or, will clinicians be caught off guard when 2019 rolls around?”

nThrive recommends diving head first into MACRA as quickly as possible. Don’t wait until the fall of 2018. Take advantage of the flexibility you are offered in Year 2. Educate yourself on the requirements, partner with an expert to help determine your technology, education, reporting and monitoring needs. Perform some practice runs to identify where problems lie. Define your reporting period – allow for at least a 90-days. Don’t hesitate, use the “transition” time wisely and get started today!

Connect with nThrive if you are unsure how to begin. We have the experts, technology and services to help your organization prepared for MACRA today and beyond.

If you’d like to receive an invitation for our upcoming MACRA Educational Webinar, “QPP Year 2, What’s Next for You?” let us know here.

To learn how nThrive will assist you in preparing for QPP Year 1, Year 2 and beyond, visit the nThrive MACRA Management Solutions page.

*The Quality Payment Program was enacted under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).