Note: This article will update as we learn more, and to reflect any changes that may happen before the rule is officially published to the Federal Register on November 23, 2018. To view the entirety of the final rule, view the unpublished pdf version.
Last night CMS released the Final Rule for the third year of the Quality Payment Program. As has been the case in the prior two years of reporting, two tracks are offered for successful participation: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). This summary will focus on the MIPS track of the QPP.
RELATED: 2019 MIPS Reporting Quick-Reference Sheet
Eligible clinician types are expanding for 2019 reporting, now to include:
Notably missing from this list are Clinical Social Workers, who were considered eligible in the proposed rule, but who became exempted based on feedback CMS obtained during the comment period. Newly eligible clinician types are exempt from the Promoting Interoperability performance category.
Additionally, the low-volume threshold will be changing slightly. Now clinicians that have ≤ $90,000 in Medicare Part B charges -OR- ≤ 200 Medicare Part B beneficiaries -OR- ≤ 200 covered professional services under the Physician Fee Schedule (PFS) do NOT have to participate in MIPS. A new option this year is for clinicians who fall under this threshold to participate if they opt to.
The performance thresholds for 2019 have become slightly more challenging:
The basic requirements of the Quality performance category aren't changing much when compared with 2018 reporting. Participants still must report six quality measures, one of which is an outcome measure. If not outcome measures apply, a high-priority measure may be used in its place. Alternatively, participants can report six measures from a specialty-specific measure set or a subspecialty specific-measure set. If less than six measures are included in the selected measure set, then all measures in the set must be reported.
For all QCDR measures, MIPS CQMs, and eCQMs, the data completeness threshold for quality measures is remaining at 60 percent. In other words, for performance data for a measure to be considered complete, at least 60% of the eligible patients or patient visits for the full year (as defined in the specifications of the selected measure) must be reported. Eligible patients continue to include patients seem from all payers.
Facility-based measures will be available for use in 2019. (more details forthcoming)
Ten new measures will be introduced:
For more details about these new measures, please refer to Table A of Appendix 1: Finalized MIPS Quality Measures. We will be providing further details about them when the full specifications are released in December.
Additionally, 26 measures will be removed:
Rationale for removal can be found in Table C of Appendix 1: Finalized MIPS Quality Measures. Generally speaking, measures were removed if they were extremely topped out (consistent performance rate between 98-100%), duplicative, not connected to improved outcomes, or not demonstrating variation in performance.
RELATED: Register for an upcoming webinar covering 2019 MIPS
Cost measure performance is captured automatically via administrative claims, so no additional submission is required. The two measures that are being utilized to determine participants 2018 Cost score, total per capita cost and Medicare spending per beneficiary, will continue to be used in 2019. Additionally, eight episode-based measures will be introduced.
CMS developed and tested eight episode-based cost measures during the 2018 performance year, representative of the cost to Medicare for items and services furnished to a patient during an episode of care. These new measures are calculated using Medicare Parts A and B FFS claims data.
Measure Topic | Measure Type |
---|---|
Elective Outpatient Percutaneous Coronary Intervention (PCI) | Procedural |
Knee Arthroplasty | Procedural |
Revascularization for Lower Extremity Chronic Critical Limb Ischemia | Procedural |
Routine Cataract Removal with Intraocular Lens (IOL) Implantation | Procedural |
Screening/Surveillance Colonoscopy | Procedural |
Intracranial Hemorrhage or Cerebral Infarction | Acute inpatient medical condition |
Simple Pneumonia with Hospitalization | Acute inpatient medical condition |
ST-Elevation Myocardial Infarction (STEMI) with Percutaneous Coronary Intervention (PCI) | Acute inpatient medical condition |
The base requirements for the Improvement Activities performance category have changed very little. The category will still be worth 15% of the MIPS final score, with full credit awarded to participants who achieve 40 points (20 points for small or rural practices, HPSAs, non-patient facing clinicians, or APM participants). Medium-weight activities remain worth 10 points, and high-weight activities worth 20 points.
There are 6 new improvement activities available for attestation in 2019:
Additionally, 1 activity has been retired:
The most obvious change to this category is found in its name - the category previously known as Advancing Care Information is now called Promoting Interoperability. However, the most impactful change that has been finalized for 2019 is the requirement to use 2015 Edition CEHRT.