The Centers for Medicare & Medicaid Services (CMS) released its “CY 2018 Updates to the Quality Payment Program Final Rule with Comment,” outlining several changes to the Merit-based Incentive Payment System (MIPS) for reporting year 2018. The Final Rule emphasizes burden reduction and other opportunities for short-term relief especially for small practices.
Disclaimer: The changes identified in this document do not represent all of the changes made between the Quality Payment Program (QPP) in 2017 and 2018. ASA will continue to update its resources as they become available.
Some changes of note include:
Low Volume Threshold: In 2017, clinicians and groups had to bill at least $30,000 in Medicare Part B charges and see 100 Medicare Part B patients within a year to meet or exceed the low-volume threshold to report MIPS. The Final Rule modifies the low-volume threshold to determine eligibility in MIPS 2018, so that a clinician or group must bill $90,000 in Medicare Part B charges and see at least 200 Medicare Part B patients within a year. This update will result in less individual clinicians being required to report MIPS in 2018 and following years.
Performance Period: For the first year of MIPS reporting CMS offered clinicians several options, referred to as “Pick Your Pace”. For 2018, the performance period for the Quality and Cost components is the 12-month, calendar year. The Improvement Activities and Advancing Care Information components must be reported for at least 90 consecutive days during the reporting year.
Ambulatory Surgery Center Based Clinicians: The Final Rule designated Ambulatory Surgery Center (ASC)-based clinicians as those who furnish 75% or more of their Medicare Part B charges in Place of Service (POS) code 24. ASC-based clinicians are exempt from the Advancing Care Information component of MIPS.
Bonuses: Clinicians and groups can receive several bonuses as finalized in the 2018 Rule. Five bonus points will be awarded to clinicians who treat complex patients based on the Hierarchical Condition Category (HCC) risk score. Small practices, defined as those with 15 or fewer clinicians will also be awarded five additional points to their final MIPS score. Points based on improvement in the Quality and Cost components will be available as well.
Quality: The Quality component will account for 50% of the total MIPS score in 2018. The data completeness minimum is 60% for the reporting year. This means, that clinicians and groups must report at least 60% of all denominator-eligible cases for each measure. A new MIPS measure – MIPS 463: Prevention of Post-Operative Vomiting (POV) – Combination Therapy (Pediatrics) – for which ASA is the measure steward, was officially added to MIPS and the Anesthesiology Measure Set.
Cost: The Cost component score for 2018 will account for 10% of the total MIPS score and will be based on two measures: Medicare Spending Per Beneficiary and Total Per Capita Cost. CMS will use administrative claims data to attribute and calculate cost scores. No specific reporting is required on the part of the clinician or group for this component. If CMS is unable to attribute data to a clinician or group, the cost score will be redistributed to the Quality component.
Improvement Activities: This component remains largely the same from 2017 and 2018 and will continue to account for 15% of the total MIPS score. Clinicians and groups can perform a combination of medium and high weighted activities totaling 40 points, each of which must be performed for 90 consecutive days. ASA is developing an updated list of Improvement Activities that may pertain to anesthesiologists and pain physicians specifically.
Advancing Care Information: This component will continue to make up 25% of the total MIPS score in 2018. In addition to non-patient facing and hospital-based clinicians, small practices (15 or fewer clinicians in a TIN) and Ambulatory Surgery Center-based clinicians are exempt from this component. The weight will be reassigned to the Quality component.
Learn more about reporting MIPS in 2018 on ASA’s MACRA webpage and the Quality Payment Program website.