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MACRA's 2018 Proposed Rule: 7 Things To Know
  • Tina Colangelo
  • Jul 06 2017

On June 20, 2017 The Centers for Medicare and Medicaid (CMS) released the highly-anticipated 2018 Quality Payment Program's (QPP) proposed rule. The 1,058-page document shows how well CMS had listened to clinician feedback requesting more flexibility, less administrative burdens and most importantly, additional opportunities to earn bonus points. 

Here is a sneak peek at what you will need to know:

  • The low volume threshold has been expanded to $90,000 Medicare Part B charges and 200 patients. This helps clinicians who may or may not be ready or do not have the resources yet to participate in MIPS. This would exclude 134,000 clinicians from MIPS in the 2018 performance year. I would encourage any clinician who does not meet the low volume threshold to take the opportunity to practice submitting all perfromance data to CMS anyway, as excluded clinicians can test their systems without getting penalized. It is a good position to be in. 
  • The 2014 EHR certification edition will suffice for those not ready to upgrade their electronic medical record systems (EMRs). Those who choose to upgrade will receive ten bonus points under Advancing Care Information (ACI) category.
  • Eligible clinicians who can demostrate rate of improvement in performance between 2017 and 2018 can receive up to 10 points in the Quality category.
  • Eligible clinicians who care for sicker patient populations will be granted a one-time special consideration, of up to 3 bonus points, becasue of patient noncompliance due to their illness.
  • Virtual groups reporting becomes an additional reporting option for smaller practices. This reporting option helps smaller practices compete with larger organizations in MIPS.
  • Hospital-based physcians can report on quality and cost categories within their facilities. This will help lessen administrative burdens.
  • Cost category takes a backseat for another year worth 0% in 2018 however will skyrocket to 30% in 2019. Cost should never be ignored despite being worth 0% in the first two years of MACRA.

It's not surprising that in 2017 MIPS has been the most popular reimbursement track of MACRA's QPP. One thing to keep in mind is that other Advanced Payment Models (APMs) will be available to participate in for 2018 performance year. They are Medicare ACO Track 1+, Next Generation ACO and Comprehensive Primary Care Plus (CPC+).

This doesn't mean complacency. It means that you are given time to restructure your business model and get up to speed. 

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