6 Highlights of the 2018 MIPS Proposed Rule

July 13, 2017

While many clinicians are still working to get a handle on the requirements for the Merit-based Incentive Payment System, they also need to keep an eye on how the program is expected to evolve next year now that CMS has released its 2018 Quality Payment Program Proposed Rule. However, those fearing the bar for penalty avoidance would be raised to unreasonable heights should breathe easy knowing CMS won’t require much more from you than what they asked for in 2017.

With that in mind, here are six of the most significant changes:


1)    Significant increase of the low-volume thresholds

CMS has proposed to raise the low-volume MIPS exemption thresholds to $90,000 in annual Medicare payments or services to 200 or fewer Medicare beneficiaries, a significant increase from the $30,000 or 100 patient thresholds for 2017. Falling below either one of these thresholds as an individual clinician will exempt you from participation, which means those who were barely over this year’s mark will most likely be exempt from the program next year.

Keep in mind, however, that the increased threshold is also applied at the group level if your group elects to report collectively.


2)    No requirements for the “Cost” category

While participants had originally been told to anticipate the introduction of a “Cost” category based on the old value modifier in 2018, CMS is now proposing to again give no weight to the fourth MIPS category next year. That being said, the agency is still soliciting feedback on whether Cost should be weighted at 10 percent of the total MIPS score for 2018, given that CMS still intends to count it as 30 percent of a participant’s score in 2019.

Regardless, CMS says it intends to track Cost progress in 2018 based on Medicare Spending per Beneficiary and total per capita cost measures. They’re also working to develop a handful of episode-based cost measures.


3)    Slight threshold increase for penalty avoidance

Clinicians who were happy with the extremely low bar set by CMS this year to avoid a Medicare penalty in the 2019 payment year should find relief in learning they won’t be asked to do much more next year to avoid a 2020 penalty. While the 2017 performance threshold of 3 (the total MIPS score required to receive a neutral adjustment) was able to be achieved by essentially submitting any quality data or completing at least one improvement activity, the 2018 threshold will be raised to just 15 points.

This can be achieved in a variety of ways, including by submitting complete data for just two quality measurements or completing the full requirements of the improvement activities category. Non-patient facing clinicians, hospital-based groups and groups consisting of 15 or fewer members will still only be required to complete either one high-weighted or two medium-weighted activities to get the full score.


4)   Automatic bonuses for small and rural practices

Given the reporting hurdles faced by small (15 clinicians or fewer) and rural practices, CMS is proposing to award an automatic five points to these clinicians scores next year. This is likely to be locked in for small practices, however, CMS is still seeking comment on whether rural practices should receive the same benefit.


5)    New facility-based scoring mechanism

No concessions for facility-based clinicians was made in 2017, but CMS is looking for change that for next year. In addition to the traditional MIPS route, the agency will implement a voluntary facility-based scoring system based on the Hospital Value Based Purchasing Program. This format will be available to clinicians who have at least 75 percent of their covered professional services supplied in inpatient hospital or ER settings. Those who choose this route would then see their facilities Total Performance Score converted into a score for their Quality performance.


6)   New quality measurements and improvement activities

Expect several new quality measurements and improvement activities to be announced alongside the final rule this fall. Specialists with fairly limited measure sets, such as pathologists, will soon have more flexibility in how they choose to participate. The College of American Pathologists is developing an additional six quality measurements that will be added to the existing eight in the pathology measure set, which is welcome news given that several of the existing measures are topped out in terms of their decile scoring range.

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