Have Your Say on 2018 MACRA Proposed Rule

More physicians will be exempt from MIPS participation next year, and what you have to do to avoid penalties will increase only slightly under the MACRA Proposed Rule for 2018, according to initial TMA staff analysis.

The draft rule outlines compliance and reporting measures for the 2018 Quality Performance Program (QPP), which includes both the Merit-Based Incentive Payment System (MIPS) fee-for-service payments and the Alternative Payment Model (APM) programs affecting Medicare payment in 2020. 

TMA staff has been analyzing the rule in detail to offer written comments by the deadline Monday, Aug. 21. Physicians may offer their own comments through the regulations.gov website, or by emailing TMA at macra[at]texmed[dot]org by Aug. 1.

The Centers for Medicare & Medicaid Services (CMS) won’t publish the final rule until fall.

TMA’s initial analysis of the draft rule found:  

  • More physicians will be exempt. CMS proposes a considerable increase to the low-volume threshold, exempting more physicians from MIPS participation in 2018 than in 2017. The proposed threshold would exclude physicians and other eligible clinicians with $90,000 or less in Medicare Part B allowed charges, or 200 or fewer Medicare Part B beneficiaries during a low-volume threshold determination period. (Up from $30,000 or 100 in 2017.) Since last year, TMA has urged CMS to set the low-volume threshold at $250,000. That would exempt physicians who have no possibility of a positive return on their investment in the cost of reporting.
  • The performance score necessary to avoid penalties is only slightly increased. CMS proposes to increase the composite performance threshold to 15, up from 3 in 2017. Practices that score 15 of the possible 100 points will avoid a MIPS payment penalty. The additional performance threshold to earn an exceptional performance bonus will remain at 70. 
  • Physicians can earn up to the minimum required 15 points by reporting only MIPS Improvement Activities. CMS proposes changing some activities and adding more to the list of 92 activities. The number of required activities will remain the same. 
  • The quality reporting period is increased, but others are not. The quality category will have a 12-month performance period, but incomplete reporting will earn a minimum of one to three points per measure. The advancing care information and improvement activities categories will continue to require a minimum of a continuous 90-day performance period. 
  • Cost measures will be calculated and reported, but still will not affect performance score. CMS proposes keeping the weight for the cost category at 0 percent. This means that cost performance in 2018 would not affect payment in 2020. 
  • Quality scoring will not change much: CMS proposes keeping the weight for the quality category at 60 percent. Data submission mechanisms and most of the quality reporting requirements will remain same. 
  • EHR requirements are slightly eased. CMS proposes offering physicians the option to use the 2014 or 2015 electronic health record (EHR) edition or a combination of the two to meet compliance and reporting requirements for the Advancing Care Information Category.
  • There are new ways to earn bonus points: CMS proposes new bonus-point policies and methodologies for MIPS categories, such as for physicians who care for medically complex patients and for those in small and rural practices.'
  • Physicians may form “virtual groups” for reporting and scoring. CMS will allow physicians to form virtual groups in 2018. This would provide solo physicians and small group practices (with 10 or fewer eligible clinicians), regardless of location or specialty, with the option to band together to form a virtual group for the purposes of MIPS participation.  

Note that any of these provisions may change when the final rule is published in the fall. 

TMA offers many resources to help you navigate the MIPS and APM pathways. Visit the TMA MACRA Resource Center to learn more. 

Action, July 5, 2017

Last Updated On

July 31, 2017

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