Key proposals for Year 3 of the QPP include:
- Expanding the definition of Merit-based Incentive Payment System (MIPS) eligible clinicians to include new clinician types (physical therapists, occupational therapists, clinical social workers, and clinical psychologists).
- Adding a third element (Number of Covered Professional Services) to the low-volume threshold determination and providing an opt-in policy that offers eligible clinicians who meet or exceed one or two, but not all, elements of the low-volume threshold the ability to participate in MIPS.
- Providing the option to use facility-based scoring for facility-based clinicians that doesn’t require data submission.
- Modifying the MIPS Promoting Interoperability (formerly Advancing Care Information) performance category to support greater electronic health record (EHR) interoperability and patient access while aligning with the proposed new Promoting Interoperability Program requirements for hospitals.
- Moving clinicians to a smaller set of Objectives and Measures with scoring based on performance for the Promoting Interoperability performance category.
- Continuing the small practice bonus, but including it in the Quality performance category score of clinicians in small practices instead of as a standalone bonus
- Streamlining the definition of a MIPS comparable measure in both the Advanced Alternative Payment Models (APMs) criteria and Other Payer Advanced APM criteria to reduce confusion and burden amongst payers and eligible clinicians submitting payment arrangement information to CMS.
- Updating the MIPS APM measure sets that apply for purposes of the APM scoring standard.
- Increasing flexibility for the All-Payer Combination Option and Other Payer Advanced APMs for non-Medicare payers to participate in the Quality Payment Program.
- Updating the Advanced APM Certified EHR Technology (CEHRT) threshold so that an Advanced APM must require that at least 75% of eligible clinicians in each APM Entity use CEHRT.
- Extending the 8% revenue-based nominal amount standard for Advanced APMs through performance year 2024.
Additionally, CMS included new language to more accurately reflect how clinicians and vendors interact with MIPS. The official CMS commenting mechanisms are outlined here.
Officially submit comments in one of the following ways:
- Electronically, through Regulations.gov
- Regular mail
- Express or overnight mail
- By hand or courier
To learn more about the PFS NPRM and the Quality Payment Program proposals, review the following resources:
- Press release - provides more detail about today's announcement
- Fact sheet - offers an overview of the proposed policies for 2019 (Year 3) and compares these policies to the current 2018 (Year 2) requirements
- Webinar - overview of the proposed rule for the 2019 performance period with the opportunity to ask questions
To learn more about QPP, visit: https://qpp.cms.gov