Beginning in 2019, eligible clinicians (including most physicians) will be paid for Medicare Part B services under the new Quality Payment Program (QPP), and they will elect to either be subject to payment adjustments based upon performance under the Merit-based Incentive Payment System (MIPS) or to participate in the Advanced Alternative Payment Model track (APM). Eligible clinicians choosing the MIPS pathway will have payments increased, maintained or decreased based on relative performance in four categories: use of information technology, clinical quality, cost and clinical improvement activities. Eligible clinicians choosing the APM pathway will automatically receive a bonus payment once they meet the qualifications for that track. CMS will publish the CY 2018 Final Rule for Quality Payment (CMS-5522-FC and IFC) in the Federal Register on November 16, 2017.
1. In CY 2018, MIPS will apply to only 40% of eligible clinicians and 66% of Part B allowed charges.
In the 2017 Final Rule, CMS estimated that MIPS would apply to approximately 59.2% of eligible clinicians while in 2018 that estimate dropped to 40%. This drop in eligible clinicians is due largely to the change in the low volume threshold exception which went from ≤ $30,000 in Part B allowed charges/OR ≤ 100 Part B beneficiaries in the 2017 QPP Final rule to ≤ $90,000 in Part B allowed charges/OR ≤ 200 Part B beneficiaries for 2018. CMS estimates that in 2018 approximately 540,347 clinicians will be excluded due to the low volume threshold exception.
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For more information on the CMS Quality Payment Program visit the McDermottPlus MACRA Resource Center or contact Sheila Madhani at (202) 204-1459 or smadhani@mcdermottplus.com.
