The MACRA rules released last November for Year 2 (2018) of the Quality Payment Program (QPP) include increased flexibility for small and independent practice clinicians participating in the Merit-based Incentive Payment System (MIPS). While the changes aim to reduce reporting burdens for clinicians, other changes happening at the agency’s leadership level present some uncertainty on the viability of the path on which MIPS will continue.
But first, looking back to 2017, MIPS-eligible physicians who participated at any level with data collection of measures in the “Pick Your Pace” models have until March 31, 2018 to submit their 2017 data for a payment adjustment in 2019.
As we enter Year 2, rules for 2018 reflect greater support of small and independent practices by implementing additional flexibilities, including:
- In 2018, many more small practices will be excluded from MIPS compliance because of a modified low-volume threshold. The new low-volume threshold is less than or equal to $90,000 in Medicare Part B allowed charges or less than or equal to 200 Medicare patients.
- Year 2 also introduces Virtual Groups. This option gives solo practitioners and groups of 10 or fewer eligible clinicians the option to come together “virtually” to participate in MIPS for a performance period of a year.
- Year 2 adds five bonus points to the practice’s final MIPS score.
- The Centers for Medicare & Medicaid Services (CMS) will continue funding the community-based organizations awarded in 2017 that provide free hands-on technical assistance to support and train physicians in practices with 15 or fewer clinicians aiming to achieve greater success with QPP/MIPS compliance. The organization serving California physicians is the Health Services Advisory Group (HSAG).
Potentially impacting the continued rollout of MIPS is the arrival of the newest Secretary of Health and Human Services (HHS), Alex Azar. Mr. Azar was confirmed by the Senate on January 24 following Dr. Tom Price’s resignation last fall. While the physician community felt it may have had a sympathetic ear in Dr. Price, with Mr. Azar, there is less certainty on how MACRA will be administered. For example, Secretary Azar has said he is open to mandatory Medicare payment demonstrations (mandatory bundled payments) that Dr. Price rejected.
On MIPS, Secretary Azar has told the Senate Finance Committee: “A key challenge under MIPS going forward will be to measure the quality of care in a meaningful way that does not require an unduly burdensome amount of time and resources.”
In January, a group called the Medicare Payment Advisory Commission (MedPAC) recommended eliminating MIPS based on the group’s assessment of the burdens imposed by the program.
Gabriela Villanueva is CAP’s Public Affairs Coordinator. Questions or comments related to this article should be directed to gvillanueva@CAPphysicians.com.