Brown, Cynthia_Cynthia.pdf · 7/19/17 1 Cynthia Brown VP, Government Affairs QPP Requirements for 2017 and Proposed Changes for 2018 2017 AAMSE Annual Conference July 28, 2017
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Transcript
7/19/17
1
Cynthia Brown VP, Government Affairs
QPP Requirements for 2017 and Proposed Changes for 2018
Some general observations • QPP created by MACRA is complex
• More than a “replacement for the SGR”
• Most of the “new” requirements are really revisions to the legacy FFS programs • Impacts of legacy programs not universally experienced or understood
• One goal of MACRA was to simplify administrative processes for physicians • Many improvements in effect now
• Additional improvements proposed for 2018
• CMS has noted its aim is participation, not penalties
• There is more work to do • Improving the practice environment is a high priority for the AMA
Low-volume threshold exemption • 2018 proposal: Clinicians with annual Medicare allowed charges of $90,000 or less, or 200 or
fewer Medicare patients exempt from QPP • Threshold increased from 2017 levels of $30,000/ 100 patients
• Eligibility calculated by CMS • Based on 12-month historical data (previous September-August)
• Includes Part B drug costs, but not Part D
• Visit www.qpp.cms.gov, enter your NPI to check eligibility for the current year
• Low-volume physicians who are members of a group that exceeds the threshold must still participate in MIPS
• Exempted physicians receive annual fee schedule updates, but no bonuses or penalties
• CMS considering a MIPS opt-in provision beginning in 2019 performance year for those below just one low-volume threshold criterion (to become eligible for bonuses)
*VBM was in effect for 3 years before MACRA passed, and penalty risk was increased in each of these years; there were no ceilings or floors on penalties and bonuses, only a budget neutrality requirement.
New proposal: Virtual Groups • Must include at least 2 solo and small group (<10) clinicians
• No restrictions on locations or specialties or number of TINs that may participate
• MIPS Virtual Group Identifiers will be created by CMS; individual clinicians identified through combination of VGI, TIN, and NPI
• All practices in virtual groups must be eligible for MIPS • A participating group may include a clinician who is not eligible (e.g., does not meet LVT), but group as a
whole must be eligible
• All eligible clinicians under the TIN would be included in the virtual group
• Requirements • Formal written agreement between each virtual group member (model agreement being developed)
• Must elect by December 1 prior to performance year
• For 2018, propose allowing election prior to final rule, in mid-September
• May only participate in one virtual group during a performance period
• Voluntary options for facility-based clinicians who have at least 75% of their covered provisional services provided in hospital inpatient or emergency department setting
• Scoring based on Hospital Value Based Purchasing Program
• For group option, 75% of eligible clinicians must beet eligibility criteria as individuals
• Scores derived using data at facility where clinician treats highest number of Medicare patients
• CMS seeking comments on-opt in vs. opt-out process
Proposed All-Payer APM combination option • Available beginning 2019 performance year
• Option only for clinicians who fail to become qualified APM participants under the Medicare only APM pathway
• Payers must submit applications to CMS, beginning for performance year 2019 • Medicaid, Medicare Advantage, and CMMI multi-payer models may submit arrangements; will be
expanded to commercial payers and other non-Medicare/Medicaid plans in future years
• Model requirements similar to Medicare advanced APMs
• 50% of clinicians must use CEHRT and clinician payments based on quality measures similar to MIPS.
• Must be a Medicaid Medical Home model similar to a Medicare expanded PCMH model or require participants to bear more than nominal financial risk.
• Qualifying All-Payer participant determination period will differ, January 1through through June 30 (vs. August 31 for Medicare APM determinations)
• 11-member Physician-Focused Payment Model advisory committee created to review stakeholder APM proposals, make recommendations to HHS Secretary
• 11 proposals submitted to PTAC, of which 3 were reviewed at April meeting:
1. Project Sonar submitted by the Illinois Gastroenterology Group and SonarMD, LLC
2. The COPD and Asthma Monitoring Project submitted by Pulmonary Medicine, Infectious Disease and Critical Care Consultants Medical Group Inc. of Sacramento, CA
3. The ACS-Brandeis Advanced APM submitted by the American College of Surgeons
• 17 additional Letters of Intent submitted with future proposals expected