QPP Year 3 Final Rule Preliminary Summary

Thursday, November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released the 2019 MPFS Final Rule, which includes changes to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) participation options and requirements for the 2019 Quality Payment Program (QPP) Year 3.

A few Highlights of the QPP Final Rule Provisions include:

  • Low Volume Threshold criteria - CMS added a third criterion to the low volume threshold criteria to provide an opportunity for certain “low volume” clinicians/groups to opt in to MIPS. This additional eligibility category is ≤200 covered professional services under the Medicare Physician Fee Schedule (MPFS) during a low-volume threshold determination period.
  • Quality Category Weighting - will be set at 45% of the total composite score, a decrease from the 2018 weighting of 50%.
  • Performance Threshold – the final composite score threshold is finalized at 30 out of 100 possible points; defines the point value that allows a provider to earn a neutral payment adjustment (i.e., avoid a -7% payment adjustment in the 2021 payment year). The exceptional performance threshold will increase from 70 to 75 points.
  • Cost – will be weighted at 15% of the total composite score for the 2019 performance year.
  • Claims-based Reporting – for 2019, this option will no longer be available to clinicians except for those in small practices (defined as 15 or fewer Eligible Clinicians within a group).
  • Topped Out Measures – For 2019, CMS is reserving the right to remove highly topped out measures in the next rulemaking cycle. Other topped out measures will remain under consideration for removal over the 4-year cycle. QCDR measures are excluded from the topped-out lifecycle and special scoring policies.
  • Promoting Interoperability (PI) - (formerly known as the ACI Category) - remains weighted at 25% of the total composite score. CMS will continue offering the various options for reweighting (i.e., exemption) and if reweighted to 0%, the score will be added to Quality weighting (i.e., move quality from 45% to 70% of the total score). Of note, the Hospital-Based (HB) status definition remains unchanged for 2019 despite stakeholder request for a revised definition.
  • Improvement Activities (IAs) –the IA category will remain weighted at 15% of the total composite score. Six (6) new activities are available, 5 were modified and 1 was removed.
  • Small Practice Bonus - A small practice bonus of up to 6 points will be available in 2019 included in the Quality performance category score of clinicians in small practices.
  • Facility Based Quality and Cost Performance Categories- In the CY 2018 QPP final rule, CMS finalized that an eligible clinician is eligible for facility-based measurement under MIPS if they are determined to be facility-based as part of a group. For 2019, CMS will implement this facility-based scoring policy resulting in CMS automatically taking the highest score of a provider, (i.e., the facility score or the individual/group provider Quality score).

We will publish more detailed specialty summaries in the coming weeks.

For More Information:

Final Rule

PFS Fact Sheet

QPP Fact Sheet