Transition and Flexibility Are the Buzzwords for QPP 2018 Proposed Rule

flexibility in QPP 2018

CMS released the proposed 2018 Quality Payment Program (QPP) rule on June 20. To sum up the 1,000+ pages, 2018 will be something of a transition year like 2017 was for QPP, which was established under MACRA. If you read through the various summaries available, you’ll see the term “flexibility” used quite often, with specialty groups adding the warning that they need time to get through the complete rule before coming to a final verdict.

Here are some areas to watch:

  • Small provider exemption and low-volume threshold: The 2017 low-volume threshold was set at $30,000 in Medicare Part B allowed charges, or 100 or fewer Part B patients. The idea was to exclude practices from QPP requirements if they were under the low-volume threshold because the burden would be too great based on their numbers. In 2018, the proposed low-volume threshold is $90,000 or less in Part B allowed charges, or less than or equal to 200 Part B patients.
  • Virtual group reporting: If you’ve got 10 or fewer practitioners in your group (or if you’re solo), there’s a proposed option to let you join with others in that size-set to be scored as a group.
  • Hospital-based provider reporting at facility level: A proposed MIPS reporting option would let hospital-based clinicians use their facility’s value-based purchasing measure results.
  • EHR certified to 2014 Edition OK: MIPS-eligible clinicians can continue to use EHR technology certified to the 2014 Edition for 2018, but you’ll get a bonus under advancing care information (ACI) for using only 2015 Edition certified EHR. One reason for this proposal is a concern about the availability of certified products.
  • MIPS scoring for cost stays at 0%: The proposed weighting is 60% quality, 25% ACI, 15% improvement activities, 0% cost. But don’t ignore cost completely. The plan is still for cost to weigh in at 30% in 2019, so you need to be prepared to handle cost when it finally counts.

What Are Societies Saying?

Each specialty, setting, and industry has its own concerns. Here are some views from just a few groups:

  • AAPMR, the American Academy of Physical Medicine and Rehabilitation, declared a “win for physiatry” after seeing a proposed update to the 2018 measure Closing the Referral Loop: Receipt of Specialist Report. The update was in line with discussions AAPMR had with CMS about reporting difficulties.
  • ASCO, the American Society of Clinical Oncology, notes it will be analyzing a provision that could make some Part B drug payments subject to MIPS adjustments.
  • AHA, the American Hospital Association, posted a statement supporting proposals and encouraging a future focus on changes that provide an incremental approach to implementation and that promote alignment of hospital and clinician efforts.

CMS is accepting comments until Aug. 18, 2017, and you can get instructions on how to submit comments on page 1 of the proposed rule.

What About You?

Do you think the proposed rule adds flexibility? Do you think it achieves the goal of moving to a value-based approach?


Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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