By Polly Friend, RN, Senior Director of Clinical Strategy, CareCloud
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was introduced in 2017 as the start of a new value-based reimbursement, set to mark the end of fee-for-service payment models. The transition to MACRA is gradual, with full implementation by year 3, with requirements for year 2 requirements just recently released the Centers for Medicare and Medicaid Services (CMS).
In Year 1, there was a great deal of confusion about MACRA and its two tracks for reimbursement: MIPS and Advanced APMs. Physicians held out hope that MACRA requirements would be repealed, only to need to rush to meet the minimum requirements to avoid negative payment adjustments in 2019 Medicare payments.
In order to avoid penalties – and potentially aim for incentives instead – here’s what you need to know about the Quality Payment Program Year 2 and how it differs from Year 1.
Eligibility and Exceptions for Year 2
- Excluded MIPS eligible clinicians or groups with less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries (up from $30,00 or 100 Part B beneficiaries in Year 1)
- Exclusions for extreme and uncontrollable circumstances (retroactive to Year 1)
- Hardship exception for the Advancing Care Information performance category for small practices
- Re-weighing the Advancing Care Information performance category to 0% of the final score for ambulatory surgical center-based MIPS eligible clinicians
- Hardship exceptions and hospital-based MIPS eligible clinicians under the 21st Century Cures Act
Changes to QPP Year 2
- Addition of virtual group participation option
- Raising the performance threshold to 15 points in Year 2 (from 3 points in Year 1)
- Weighing the MIPS Cost performance category to 10% of your total MIPS final score (CMS will calculate this with MSPB and total per capita cost measures)
- Changing the Quality weight to 50% in 2020 payment year and 30% in 2021 payment year, with lower point values for incomplete data (see chart)
- The introduction of topped-out measures
- Provisions to make it easier for eligible clinicians to participate in Advanced APMs, including an extension of the 8% generally applicable revenue based nominal amount standard that allows APMs to qualify as Advanced APMs, changing the requirement for Medical Home Models, easier ability to participate in Advanced APMs that begin or end in the middle of a year
New Incentives for Year 2
- Bonus points for using a 2015 CEHRT
- Up to 5 bonus points for the treatment of complex patients
- Up to 5 bonus points for small practices
- 3 bonus points for small practices for measures in the Quality performance category that don’t meet data completeness requirements
- Greater incentives for clinicians who participate in APMs
For organizations aiming for incentives, check out “The Top 5 MIPS Questions Answered” and stay tuned for my next post about aiming for incentives under APMs.
