The 2019 Proposed Rule for Year Three of the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program (QPP) has been published by the Centers for Medicare and Medicaid (CMS). Notable in this latest release is that while previous years’ regulations for the QPP have been released independently, for calendar year 2019 CMS has included proposed rules for the Medicare Physician Fee Schedule (MPFS). While MPFS dictates policies and procedures for Medicare rates under Part B benefits, QPP implements the two key value-based programs that provide payment of fees via a clinician’s participation in the Merit-based Incentive Payment System (MIPS) or the Alternative Payment Models (APMs).
An emerging theme for Year Three is the priority by CMS to reduce reporting burdens and to continue to shape policies that will further clinicians’ access to all health information on their patients by increasing interoperability. In an announcement published on the CMS website, CMS Administrator Seema Verma stated, “Today’s proposals deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients. Physicians tell us they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care.”
According to CMS, removing paperwork requirements from the physician fee schedule (MPFS) would save individual clinicians an estimated 51 hours per year if 40 percent of their patients are in Medicare. In combination with streamlined documentation requirements under MIPS, this will help clinicians spend more time focusing on patient care as well as reduce administrative costs, CMS asserts.
Of note, the MIPS Year Three rule proposes the following flexibilities for clinicians in small practices:
- Continuing the small practice bonus, but placing it in the Quality Performance Category score of clinicians in small practices instead of as a standalone bonus
- Awarding small practices the minimum three points for quality measures that don’t meet the data completeness requirements for the maximum of 10 points.
- Consolidating the low-volume threshold determination periods with the determination period for identifying a small practice.
Overall, the proposed rule for Year Three consists of almost 1,500 pages, drawing both supporters and critics. Two criticisms of the proposed rule were expressed by the Medical Group Management Association (MGMA), which points out that CMS will continue requiring physicians to document a full 365 days of quality measures and that physicians will be required to use a 2015 Edition EHR system starting in 2019 — a requirement that might involve a significant financial burden.
The deadline to submit a comment to CMS on the 2019 Proposed Rule is September 10, 2018.
Useful Links
A fact sheet that offers an overview of the proposed policies for 2019 (Year Three) and compares those policies to the current 2018 (Year Two) requirements can be found at
https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-QPP-proposed-rule-fact-sheet.pdf
To submit comments on the proposed rules, visit https://www.regulations.gov/comment?D=CMS-2018-0076-0001
Gabriela Villanueva is CAP’s Public Affairs Analyst. Questions or comments related to this article should be directed to gvillanueva@CAPphysicians.com