The 2018 MIPS Proposed Rule was just released by CMS, and it contains changes from the 2017 rule which providers may benefit from considering in relation to their reporting goals and strategies. In our last post we outlined various new proposals as well as new opportunities for bonus points in the MIPS final score. Here we clarify further changes from 2017, including updates on the low volume threshold, submission options, and the minimum performance period.
The Low-Volume Threshold
For 2018, the low-volume threshold is proposed to be more inclusive. Currently, the low-volume threshold excludes otherwise eligible clinicians or groups that have ≤$30,000 in Medicare Part B allowed charges or ≤100 Part B beneficiaries. This is proposed to be increased to excluding clinicians who have ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries. Like with the 2017 performance year, low-volume threshold eligibility will be determined during a period of time that takes place during or prior to the performance period.
Currently, eligible groups and clinicians must report all their data for one performance category through the same submission mechanism. For example, for the Quality Performance Category, one could not submit 3 measures through their EHR and 3 different measures through a qualified registry and expect them to be looked at as 6 measures. For the 2018 performance year, this is proposed to change, allowing providers to report each category through a hybrid of mechanisms if they choose to. This could be particularly beneficial for health systems who have multiple EHRs or internal processes.
Minimum Performance Period
In 2017, an eligible clinician or group can report for a minimum of 90 days across all performance categories. For the 2018 performance year, the 90 day performance period can only apply to the Advancing Care Information and Improvement Activities Performance Categories. Both Quality and Cost will be measured for the entire calendar year.
CMS hopes to achieve improved health outcomes, wiser spending, a minimal reporting burden, and a fair and transparent system through this proposed ruling. If you have comments or feedback about these proposals, you should weigh in before August 18, 2017. Comments can be made through mail or electronically through regulations.gov, referencing file code CMS 5522-P.
 Unpublished Proposed Rule: Medicare Program; CY 2018 Updates to the Quality Payment Program
 Quality Payment Program Proposed Rule Fact Sheet