Webinar Recap: Quality Payment Program Year 2, what’s next?

By nThrive | Posted: 12/11/2017

The MACRA Quality Payment Program Year 2 regulations were released a little over a month ago and although they incorporate many of the flexibilities from the transition year, we’ve found many health care leaders are still seeking clarification to determine how best to proceed beginning January 1, 2018.

At nThrive’s recent webinar, “Quality Payment Program Year 2,” expert Moshe Starkman, nThrive senior value-based reimbursement (VBR) consultant, shared MACRA’s Quality Payment Program (QPP) Year 2 requirements while contrasting the transition year (Year 1) and Year 2 changes. We’ve compiled the most asked questions below to help demystify the 2018 QPP final rule.

Q: It doesn't seem like much is changing, practically speaking, from the 2017 to 2018 QPP. It seems like more of the same, but at a higher minimum-score threshold. Is this right?

A: The 2018 Quality Payment Program (QPP) Year 2 has been coined by many as the “second transition year.” CMS will continue down the payment reform path with the aim of increasing quality and lowering cost through technology to minimize MACRA’s regulatory burden on its eligible clinicians.

The Year 2 rule reduces the regulatory burden by providing additional flexibility to clinicians, with special focus on small practices and solo practitioners. In 2018, CMS will exempt clinicians and groups with less than $90,000 in Medicare Part B allowed charges or 200 or fewer Medicare Part B patients. The 2018 rule adds an additional 123,000 clinicians to the MIPS exemption list.

In addition to low volume threshold clinician exemptions, CMS expects more clinicians to qualify for Advanced Alternative Payment Models (APMs), allowing them to avoid MIPS participation.

To read about the Quality Payment Program’s MIPS category changes, go here.

Q: I’m confused about the cost category. It is 10 percent of our performance score, or it is weighted at zero for 2018?

A: The cost category did indeed change between Year 1 and Year 2, which can lead to some confusion. In Year 2, the 2018 reporting year, the cost category will impact a clinician’s final MIPS performance score. Cost will be scored and weighted at 10 percent of the final score. Whereas in Year 1, the 2017 reporting year, the cost category – even though it will be scored – will not impact a clinician’s final MIPS performance score as it will be weighted at zero percent. However, CMS will provide clinicians with feedback on their cost performance as a point of reference for future reporting years.

CMS will utilize claims data to calculate the cost measures of a clinician’s performance for Year 1 and Year 2, so no additional data submission is required for the cost category for either year. The increase in the scoring percentage weight is an effort by CMS to help clinicians prepare for the 2019 performance period, when it jumps to 30 percent of the MIPS final score.

Q: How do bonus points work in 2018? Specifically, the small practice bonus and the performance improvement bonus?

A: In 2018, CMS is working to alleviate MIPS burdens for small practices and groups. For practices of 15 or fewer clinicians, a five percent bonus will be awarded when data is submitted for at least one performance category. If a clinician’s patient population is deemed particularly complex, a severity bonus of up to five bonus points, as measured by a combination of the number of dually eligible patients treated and the Hierarchical Conditions Category (HCC) risk scores, can be awarded. Clinicians can also be awarded a performance improvement bonus of up to 10 percent for score improvement in the quality and/or cost categories, regardless of practice size. Both the severity bonus and performance improvement bonus encourage stronger coding practices and can collectively be the difference between a gain or loss of up to 15 percent of your final performance score.

Q: Are multiple submission mechanisms allowed for Year 2?

A: Although CMS hinted at allowing practitioners to submit data through multiple mechanisms for the Year 2 (2018) performance period, practitioners will have to wait for that option until 2019. According to CMS, "Due to operational reasons and to allow additional time to communicate how [a multiple submission mechanisms] policy intersects with our measure applicability policies, this policy will not be implemented for the 2018 performance period but will be implemented instead for the 2019 performance period of the Quality Payment Program." This was a last-minute change that many aren’t aware of but is important to note when devising your future QPP strategy.

QPP Concerns Prevalent

Although the 2018 final rule continues to provide some of the flexibility offered in 2017, it doesn’t fully resolve the concerns practitioner groups have voiced associated with the complex reporting and scoring rules of the MIPS program. Instead, Year 2 only illustrates the movement forward to usher in the increased demands inherent to the QPP.

As Erica J. Kraus so eloquently points out in her National Law Review blog post, MIPS does not have long term prospects in its current state. “In the very short time frame that CMS has left providers to accommodate some of these demands is discouraging and lends credence to MedPAC’s recently expressed concern that the MIPS program will create significant practitioner burden associated with its complex reporting and scoring rules,” writes Kraus. “In fact, the Final Rule did not address or mitigate either these concerns or MedPAC’s concerns about elements of the MIPS scoring structure that may lead to limited ability to detect meaningful performance differences and to inequitable scoring.”

If you have not yet begun to actively prepare for Quality Payment Program long-term strategies, the time is now to take the leap into the world of value-based reimbursement. Engage with nThrive and we will help your practice find success in your journey from volume to value.

If you’d like to receive an invitation for our upcoming MACRA educational webinar series, let us know here.