When Congress finalized the fiscal 2017 federal budget on February 9, 2018, the bill1 contained some changes that will affect the Medicare Quality Payment Program (QPP) in the coming years. Nothing in the bill changes Medicare payment levels or the MIPS2 reporting requirements for 2018. There is, however, a change that affects the 2018 performance year low-volume exclusion.
Here is a summary of the changes:
| Revised Provisions | Original Provisions |
| Full MIPS implementation will be deferred until the 2022 performance period. | The transition period was to end with the 2018 reporting period; full MIPS was to be in effect for 2019 reporting. |
| The Cost Category must now be 30% of the Final Score by the 2022 performance period. | The MIPS Cost Category was to be 30% of the Final Score by 2019. |
| Year-over-year Cost Category improvements will not become a factor in the Final Score until 2022. | Improvement in Cost Category scores was to be factored into the Final Score beginning with 2018 performance. |
| MIPS payment adjustments will be applied only to Part B “covered professional services.” There will be no adjustment for other Part B payments, such as drugs. | MIPS payment adjustments beginning in 2020 (for 2018 performance) were to be applied to all Part B Medicare services. |
| The 2018 low-volume threshold will only include Part B “covered professional services.” This omits other Part B payments for things such as drugs from the calculation. | The 2018 low-volume exclusion of $90,000 or 200 patients included all Part B services. |
The extended transitional period (2019 – 2021) will allow for a gradual and incremental transition of the MIPS performance threshold toward the 2022 mandated value. The threshold, currently at 15 Final Score Points for 2018, is the minimum level of participation in MIPS that will allow the practice to avoid a payment penalty. When fully implemented, the performance threshold must be the mean or median of national historical MIPS scores. During this transition period, the MIPS Cost Category will also be gradually increased from 10% to 30%.
The change to the low-volume threshold could have immediate impact in 2018 for small practices, however. By eliminating items other than professional services from determination of the total amount billed to Medicare, small practices that use many and/or expensive Part B drugs or other separately billed items may find that they are exempt from MIPS participation in 2018. We continue to recommend that practices take every opportunity to begin MIPS participation whether it is required or not, so that when the time comes they are prepared to attain the best score possible.
The stated goal of the QPP is to move physicians into value-based payment systems, such as the Advanced Alternative Payment Models (APM) that represent the other participation track currently available under the QPP. The changes enacted in the BBA 2018 will allow physicians to remain in MIPS for a longer period before switching over to APM participation. The factors that influence a practice’s decision to move toward APM participation rather than to remain in MIPS will be the subject of an upcoming analysis in our blog. Subscribe now to be the first to know when it is available.
Richard Morris is the Director of Value-Based Strategy at Heatlhcare Administrative Partners.
1The Bipartisan Budget Act of 2018 (BBA 2018)
2Medicare Incentive-based Payment System, one of two tracks for physicians to participate in the QPP.
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