CMS proposes raising low-volume exemption, adding virtual groups in MACRA’s second year

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The proposed rule for the second year of the Medicare Access and CHIP Reauthorization Act’s (MACRA) Quality Payment Program (QPP) has been released by CMS, with its stated goal to “simplify the program, especially for small, independent, and rural practices, while ensuring fiscal sustainability and high-quality care.”

CMS Administrator Seema Verma said in her statement that the agency sought to address concerns about MACRA increasing reporting and technology burdens on physicians, as well as making it easier for rural and smaller providers to participate.

“That’s why we’re taking a hard look at reducing burdens,” Verma said. “By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork. CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.”

The rule is even longer than the first MACRA proposed rule, coming in at 1,058 pages.

The most striking change to the program is raising the low-volume threshold for the Merit-based Incentive Payment System (MIPS). In 2017, clinicians are exempt from MIPS if they receive under $30,000 in Medicare Part B charges or treat fewer than 100 Medicare patients. In 2018, CMS is proposing raising those thresholds to $90,000 in Part B charges and 200 patients.

While CMS said in the proposed rule this would “enhance the ability of small practices to participate,” the existing low-volume thresholds had already exempted 65 percent of Medicare providers in its first year.

Other changes in the proposed rule include:

  • Adding a “significant hardship exception” from the advancing care information performance category for MIPS eligible clinicians in small practices
  • Adding bonus points to MIPS scores for clinicians in small practices as long as they submit in one performance category
  • Continuing to allow the use of 2014 Edition CEHRT (Certified Electronic Health Record Technology), while encouraging the use of 2015 edition CEHRT.
  • Creating a “virtual group” participation option which would be composed of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” with at least 1 other such solo practitioner or group to participate for one performance year.
  • Implementing facility-based measures to “add more flexibility for clinicians to be assessed in the context of the facilities at which they work."

The rule is due to be published on the Federal Register on June 30, with comments being accepted through August 21.