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Society weighs in on changes to Quality Payment Program

The Wisconsin Medical Society submitted comments last week to the Centers for Medicare and Medicaid Services on proposed changes to the Quality Payment Program (QPP) required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Released in June, the 1058-page proposed rule makes changes in the second year of the Quality Payment Program (QPP) as required by MACRA. The proposal aims to simplify reporting requirements, which would help physicians avoid penalties under the QPP, and offer support for physicians and clinicians in 2018. (For a fact sheet on the proposed rule, click here.)

The biggest proposed changes are raising of the low-volume threshold and an option allowing physicians to participate in “virtual groups” in year two of the QPP. Proposed updates also include changes to both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) programs.

The low-volume threshold for participation in the QPP would be increased from $30,000 per year in allowed Part B charges or less than 100 Part B beneficiaries up to $90,000 per year or 200 Part B beneficiaries. Physicians whose charges or numbers are below these thresholds would be exempt from participation in the QPP. CMS estimates that under this new threshold, approximately 37 percent of all physicians would be required to participate in the QPP.

The proposed rule also allows physicians to elect into a “virtual group” as “another way for clinicians to elect to participate in MIPS (the Merit-based Incentive Payment System).” To participate through a virtual group, physicians would have to meet the requirements of a MIPS-eligible clinician (as a solo practitioner), or be part of group of 10 or fewer eligible clinicians. Solo practitioners would be allowed to join groups of 10 or fewer clinicians to form their own virtual group, regardless of location or specialty. Some of the benefits of a virtual group are that the entire group would be scored on their combined performance for quality and cost under the QPP, as well as provide group support for reporting, training and assistance and a combination of resources.

Other proposed updates to the QPP include changes to the MIPS program including data completeness thresholds, status of “topped-out” measures, cost reporting, improvement scoring, advancing care information and bonuses for small practices and the treatment of complex patients. Changes to the Advanced Alternative Payment Models (APM) program include adjustments to the nominal risk standard, creation of new performance periods for the all-payer combination option, and allowing virtual groups to participate in MIPS APMs.

Click here to read the Society’s comments on the proposed changes. The American Medical Association (AMA) also submitted these comments.

The Physicians Advocacy Institute (PAI) and the AMA each have developed education resources to help physician practices succeed under the QPP. More information and links to these resources is included in this Medigram article.

For more information about the Quality Payment Program, please visit qpp.cms.gov. If you have any questions or comments, please contact H.J. Waukau at 608.442.3807.

Back to August 31, 2017 Medigram