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Quality Payment Program Final Rule

11/03/2017 3:35 PM | Anonymous

The Quality Payment Program (QPP) Final Rule was released last night. We are still reviewing every detail and considering comments to submit, but below you will find some of the big points we have pulled out so far.

  • Threshold to avoid a penalty moves from 3 to 15 MIPS points
  • 2014 and/or 2015 CEHRT allowed but bonus ACI points available if use only 2015 CEHRT
  • Eligible clinicians or groups with <= $90K Part B allowable or <= 200 Part B beneficiaries excluded
  • Cost category counts for 10% of MIPS score
  • Cost category score will be calculated by Medicare Spending per Beneficiary (MSPB) and total per capita cost measures
  • CMS will calculate Cost measure “performance” - nothing for us to report for that category
  • Clinicians affected by Harvey, Irma, or Maria that do not submit 2017 MIPS data will not have a negative adjustment in 2019
  • Clinicians affected by Harvey, Irma, or Maria can file a hardship exception application for Quality, ACI, and CPIA categories for 2018 performance period
  • Still only allowed one submission method per category
  • Quality category moves from 60% of MIPS score in 2017 to 50% in 2018
  • Clinical Practice Improvement Activity category still counts 15% - can still avoid penalty with just a perfect CPIA score
  • Clinicians in practices of 15 or less are exempt from ACI category and that 25% moves to Quality category
  • Exceptional performance threshold remains 70 MIPS points
  • Option to participate as a Virtual Group
  • 2018 QPP Final Rule Reporting Periods: Cost - 12 mos, Quality - 12 mos, ACI - 90 days, CPIA - 90 days
Links: Full Release / CMS Summary Sheet

Nothing discussed in this communication guarantees coverage or payment. This is our interpretation of the Final Rule. Coverage and payment policies of governmental and private payers may vary from time to time and in different parts of the country. Questions regarding coverage and payment by a payer should be directed to that payer. APWCA does not claim responsibility for any consequences or liability attributable to the use of any of the information discussed in this communication.

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