2018 Quality Payment Program Proposed Rule Lands at OMB

This week the Centers for Medicare Medicaid Services (CMS) sent the 2018 Quality Payment Program (QPP) Proposed Rule (CMS-5522-P) to the Office of Management of Budget (OMB) for review. Established through the Medicare Access and CHIP Reauthorization Act (MACRA), the QPP established two tracks for Medicare physician payment: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMS). For 2017, the first performance year of the Quality Payment Program (QPP), CMS introduced the “Pick Your Pace” program which reduced participation requirements to avoid MIPS penalties in 2019. Under Pick Your Pace, Eligible Clinicians only need to submit a single quality measure to avoid a 2019 negative payment adjustment.

Additionally, CMS did not implement the Cost Performance Category in 2017. Cost is one of four MIPS Performance Categories. CMS indicated in the 2017 Final Rule that the Cost Performance Category would account for 10 percent of the MIPS score in 2018. Providers and other stakeholders are eagerly anticipating its release for the agency’s proposals on the Cost Performance Category and other increased QPP participation options for 2018.

The OMB review typically is the last step in the review process before a rule is released. While the OMB can take up to 90 days to review the rule, and can extend that 90 days if needed, in numerous recent public comments. It is anticipated that CMS intends to publish the QPP Proposed Rule in April or May 2017.


Click here to access the McDermottPlus MACRA Resource Center.

For more information please contact Sheila Madhani at 202-204-1459 or smadhani@mcdermottplus.com.