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Key Highlights from the 2018 QPP Final Rule

The final rule for Medicare’s Quality Payment Program for 2018 was released on November 2, 2017. It is available from the federal register here.

Medicare’s executive summary is accessible here and gives a great side-by-side comparison of the rules between 2017 and 2018.

Highlights of the Final Rule, as represented in the executive summary, include good news for small practices.
  • The MIPS low-volume exclusion is increased to ≤ $90,000 in Medicare Part B Allowable charges or ≤ 200 individual Medicare patients.
  • Small practices can earn bonus points toward their Final Score, just by being “small.”
  • Small practices can still earn a minimum of three points in Quality just for submitting “some data.”
  • Small practices can be exempt from ACI.
  • Small practices can join Virtual Groups for 2018 with a self-nomination deadline of December 31, 2017, extended from the original deadline proposed of December 1, 2017.
Cost is back, a year earlier than was proposed.
  • For the 2018 performance year, the quality performance category will be weighted at 50% of the Final Score and cost will be weighted at 10%.
  • The cost performance category for 2018 will include “Total per capita costs for all attributed beneficiaries” and “Medicare Spending per Beneficiary.” No episode measures will contribute to 2018 performance year cost scoring.
The Quality performance category got a little harder.
  • Data completeness criteria advances from a minimum of 50% of patients eligible for each measure to 60%. This percentage is expected to be applicable for both 2018 and 2019 performance years and a full year of data must be reported. Ninety days for quality is no longer considered complete.
  • For larger practices, measures not meeting the data completeness criteria or case minimum earn just one point instead of three.
Reporting the Advancing Care Information performance category just got a little easier.
  • There are exclusions retroactive to 2017 for the e-prescribing and HIE-related measures.
  • There are new exemptions from ACI for small practices.
  • 2015 CEHRT is not required but if you use it, you will earn bonus points for ACI.
  • The measures remain the same with some minor differences and clarifications for several.
Minor changes to the Improvement Activities performance category were implemented.
  • More activities added but number of activities required and scoring remains the same.
Overall, notable highlights from the Final Rule also include:
  • The bar got a little higher for avoiding penalty. It now requires 15 points instead of just 3.
  • The exceptional performance bonus threshold remains at 70 points.
  • There is a new retroactive Automatic Extreme and Uncontrollable Circumstance Policy applicable for natural disasters. It will be retroactively applied to practices affected by hurricanes Harvey, Irma, and Maria in 2017 and any disasters yet to come in 2017 and years following. It will be applied automatically to practices Medicare identifies as being in the affected areas.
  • Practices treating complex patients can earn a potential five points toward the Final score.
  • There are new bonuses applicable to improvements in cost and quality performance scores. Cost performance improvement will be calculated at the measure level. Quality performance improvement will be calculated at the level of the combined quality performance score.

Continue monitoring the Mingle Analytics Blog for additional articles on various Final Rule topics as we dig deeper into the rules. Have a question? Contact us now, or submit it via the comments section below.

Want a more in-depth look at the 2018 Final Rule? Join Dr. Dan Mingle, founder and CEO of Mingle Analytics, for his upcoming webinar, The 2018 Quality Payment Program Final Rule – in Plain English, to receive concise overview.

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