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Physician Payment Reform

The passage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Sustainable Growth Rate (SGR) and replaced it with two new payment update tracts, the Merit-based Incentive Payment System (MIPS) and CMS Alternative Payment Models (APMs). The MIPS and APM programs are scheduled to go into effect January 1, 2019.

MACRA created the MIPS to replace/
the current CMS Quality Initiative
Programs. MIPS incorporates aspects
of several CMS quality programs into
a component score to determine physician payment.

Learn More about MIPS

APMs are a class of payment reform 
that incorporates quality and total
cost of care into reimbursement
rather than a traditional fee-for-service
structure.

Learn More about APMs

CMS Releases Final Quality Payment Program for CY 2018 - 11/9/2017

On November 2, the Centers for Medicare and Medicaid Services (CMS) issued the final rule for Year 2 of the Quality Payment Program (QPP), addressing 2018 requirements and future years under the Merit-Based Incentive Payment System and the Advanced Alternative Payment Model programs. An interim final rule was also released for extreme and uncontrollable circumstances where clinicians can be automatically exempt from these categories  in the transition year without submitting a hardship exception application, if they were affected by Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period. The Academy will submit comments by the January 1, 2018 deadline. 

  • Access the final rule here
  • Read the CMS Year 2 Fact Sheet here
  • Review the Executive Summary here

Quality Payment Program (QPP) Hardship Exception Application for the 2017 Transition Year is Now Open

The QPP Hardship Exception Application can be found on the QPP website. MIPS eligible clinicians (ECs) and groups may qualify for a reweighting of their Advancing Care Information (ACI) performance category score to 0% of the final score, and can submit a hardship exception application, for one of the following specified reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
    • Disaster (i.e., natural disaster in which the Certified EHR Technology (CEHRT) was damaged or destroyed)
    • Practice or hospital closure
    • Severe financial distress (bankruptcy or debt restructuring)
    • EHR certification/vendor issues (CERHT issues)
  • Lack of control over the availability of the CERHT

In addition to submitting an application via the QPP website, ECs may also contact the QPP Service Center and work with a representative to  verbally submit an application. 

To submit your application, you will need:

  • Taxpayer Identification Number (TIN) for group applications or National Provider Identifier (NPI) for individual applicants;
  • Contact information for the person working on behalf of the individual clinician or group, including first and last name, e-mail address, and telephone number; and 
  • Selection of the hardship exeception category (listed above) and supplemental information

Applications will be processed on a rolling basis. Once an application is submitted, a confirmation email will be sent out to indicate status as pending, approved or dismissed.

You may contact the QPP Service Center by calling 1-866-288-8292 or TTY: 1-877-715-6222. You may also email them at QPP@cms.hhs.gov

Summary of Proposed 2018 MIPS and APM Reporting Requirements 
On June 20, CMS released the 2018 proposed rule for the MIPS and APM programs. The proposed rule includes details on MIPS performance category reporting for 2018, details on upcoming Virtual Group participation, available exclusions including the low-volume threshold for 2018, and APM requirements and definition. The proposed rule and a CMS proposed rule fact sheet can be found on CMS' resource library. For questions regarding 2018 proposed requirements, contact the Health Policy team at healthpolicy@entnet.org

The Academy has published a summary of the 2018 MIPS and APM reporting requirements for Otolaryngologists, including details on proposed provisions directly affecting your practices. Access the Academy summary document here

CMS Releases New Quality Payment Program (QPP) Resources
CMS has added additional resources to the QPP website to help clinicians participate in the MIPS and APM programs. Resources include a MIPS Quick Start Guide and updated fact sheets. Clinicians can also access a web tool on the QPP webpage to check their MIPS participation status. Clinicians can access these resources on the QPP webpage here. 

Academy Comments on Post-SGR Payment Policy with CMS MIPS and APM Final Rule
On December 19, the Academy commented on the final rule released by CMS that solidifies the details of the two new payment update tracks, the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). These programs were created by the historic legislation that repealed the SGR, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In the final rule, CMS adjusted several key aspects of the program that Academy submitted comments last spring. Important changes to the program include:

  • Clinicians have the option to pick their pace with three reporting periods for MIPS:
    • Test Pace: Report some data in 2017.
      • 1 quality measure, or 1 improvement activity, or 4/ 5 required advancing care information (ACI) measures.
    • Partial MIPS Reporting: Report one or more MIPS categories for at least 90 consecutive days in 2017 (must begin reporting by October 2, 2017).
      • 1+ quality measure, or 1+ improvement activities, or 4/ 5 required ACI measures
    • Full MIPS Reporting: Report all MIPS categories for at least 90 consecutive days in 2017 (must begin reporting by October 2, 2017).
  • The low volume threshold excluding clinicians from MIPS reporting was increased to “Medicare billing charges of more than $30,000, and provide care to more than 100 Medicare patients per year.”
  • For CY 2017 only, CMS eliminated Cost as a MIPS reporting category. In CY 2018, MIPS participants will receive cost scores based on adjudicated claims data.

The Academy commented on the reduced reporting requirements for the transition year; MIPS performance category criteria and scoring; Qualified Clinical Data Registry (QCDR) and quality measure reporting requirements; and applicability of APMs to Otolaryngologists - Head and Neck Surgeons. The Academy's comments are available here.