Our Take on the Final QPP Rule

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Summary

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released a final rule that makes changes to the second year of the Quality Payment Program (QPP) for 2018. The QPP was created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
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The final rule implements changes to the two pathways for clinicians participating in Medicare Fee-for-Service: (1) the Merit-Based Incentive Payment System (MIPS) and (2) Advanced Alternative Payment Models (Advanced APMs).

Some of the major provisions in the final rule include:

  • Exempting clinicians from MIPS participation, who see fewer than 200 patients for 2018;
  • Allowing clinicians to band together virtually so that they may meet the reporting requirements and be eligible for the MIPS bonus;
  • Weighting cost at 10% for 2018 reporting;
  • Granting Medicaid, Medicare Health Plans, and CMS Multi-Payer Models the ability to submit Advanced APMs for plan year 2019; and
  • Including the cost Part B medicines in the payment adjustment to clinicians.

“Today’s final rule reflects the Administration’s continued commitment to providing flexible participation options for clinicians,” said Nelly Ganesan, senior director at Avalere Health. “We expect CMS will continue to seek input on implementation and execution of program elements.”

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