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QPP Year 3 Proposed Rule – Objectives & Revisions

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The Quality Payment Program (QPP) has been well received by clinicians with over 90% of eligible clinicians participating in the MIPS 2017 performance period. Over the last 2 years, QPP has been progressing on the path to reduce regulatory burden, present flexible participation options and allow clinicians to spend more time with patients. Amendments in the proposed rule for Year 3 (2019 Reporting Year) reflect the stakeholders’ feedback and focus on alignment of the program to its strategic goals.

Following are the major objectives which form the basis of the proposed rule:

  • Implementing the Meaningful Measures Initiative: Patient centered approach to prioritize meaningful outcomes, remove low-value process based measures leading to improved care quality and reduced regulatory burden for clinicians
  • Promoting interoperability: Allow easy access, exchange and use of electronic health information to patients and providers
  • Supporting small and rural practices: Continue to help small practices through no-cost resources and regulatory adjustments
  • Patients over paperwork initiative: Empower patients to participate in their own healthcare decisions and capitalize fund advanced quality measure development
  • Promoting price transparency: Enable patients to make informed healthcare choices, driving health data portability, encourage competition and lower healthcare costs.

A few of the notable proposals for 2019 along with revision areas are listed below:

MIPS Overall Updates:

  • MIPS Eligibility Expansion: MIPS eligibility has been enlarged to include physical therapists, occupational therapists, clinical social workers, and clinical psychologists as new clinician types
  • Low-Volume Threshold (Opt-In): Added addition of a 3rd criterion for Low Volume Threshold i.e. provide ≤ 200 covered professional services, clinicians can now choose to opt-in to MIPS if they meet or exceed >= 1 criteria
  • EHR Certification Requirements: Eligible clinicians are mandated to use 2015 Edition CEHRT from 2019 Reporting Year, eventually discontinuing the transition measures. Addition of API functionality to support physicians and patients for an easy access and exchange of health information.
  • Reporting & Submission Terminologies: Submission Mechanism and Reporting is replaced with new terms as mentioned below:

    1. Collection Types: eCQMs, MIPS CQMs, QCDR measures, CMS Web Interface measures, and administrative claims measures etc.

    2. Submitter Types: Individual ECs, Groups or 3rd party data submitters

    3. Submission Types: Direct, log in and upload, log in and attest etc

  • Performance Threshold: Significant increase in the MIPS performance threshold points i.e. 30 points in 2019, exceptional performance at 80 points. Payment adjustment ranges from -7% to +7%

MIPS Category-wise Modifications:

  • Promoting Interoperability: Weightage 25%
    1. Base, Performance & Bonus scoring logic replaced with a new scoring logic. Each measure has a performance score contribution with certain measures required to be reported. The measures fall under 4 major objectives:

      1. e-Prescribing

      2. Health Information Exchange

      3. Provider to Patient Exchange

      4. Public Health and Clinical Data Exchange

    2. Removed 6 existing measures, added 3 new measures and modified 2 measures
    3. Discontinued the bonus for IAs using CEHRT
  • Quality: Weightage 45%
    1. Allowed the combination of collection types to report measures and renamed "Registry Measures “to "MIPS CQMs"
    2. Retained the basic scoring methodology and the bonus points for:
      1. High priority measures

      2. Complex patients

      3. End-to-end electronic reporting

    3. Included the bonus for Small Practices under Quality
  • Cost: Weightage 15%
    1. Gradual increase of 5% in contribution towards Final Score
    2. Added 8 new episode based measures
  • Improvement Activities: Weightage 15%
    1. Added 6 New IAs, modified 5 existing IAs and removed One IA
    2. Adopted an additional criterion “Include a public health emergency as determined by the Secretary”

APMs Revisions:

  1. Mandated Advanced APMs to use CEHRT by at least 75% ECs
  2. Allowed QP determination at TIN level, giving more flexibility under All-Payer Combination option
  3. Clarified MIPS APMs requirements for Quality & Cost measures and updated the measure sets for APM Scoring Standard
  4. Streamlined the definition of MIPS comparable measure in order to avoid confusion

Take Away from the Proposed Rule

  1. Overhauled the Promoting Interoperability category to emphasize on health information exchange for both patients and providers
  2. Focused on outcome based quality care, meaningful measures and simplifying reporting requirements to reduce burden on clinicians
  3. Underlined the importance of patient engagement to improve the patients’ role in managing their own care through the use of APIs
  4. EHRs mandated to be upgraded to 2015 Edition CEHRT from 2019 reporting year
  5. Providers are expected to improve MIPS performance to meet the increased threshold and avoid penalty for 2019 reporting year

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