MACRA 2018 Proposed Rule Update

The Medicare Access and CHIP Reauthorization Act of 2015 gave rise to the CMS Quality Payment Program.  In 2017 CMS provided options that allow clinicians to avoid penalties under MACRA fairly easily.   CMS released a Proposed Rule for the Quality Payment Program for the 2018 reporting year in June of 2017.  It continue with many of the same relaxations as 2017, however there are some notable differences as highlighted in the table below.

MACRA RequirementMACRA 2017MACRA 2018 (Proposed)
MIPS Eligibility (Part B Payment)More than $30,000 per yearMore than $90,000 per year
MIPS Eligibility (Part B eligible patients seen per year)More than 100More than 200
Quality Measure Data Reporting Period90 days or more (to achieve the highest possible score)365 days
Use of 2015 Edition CEHRT (Stage 3)Required conversion in 2018Relaxed conversion in 2018, 2014 edition remains optional
MIPS Performance Threshold3 points15 points
MIPS APM Participant Snapshot DatesMarch 31, June 30 and August 31March 31, June 30 August 31, and December 31
MIPS APM MeasuresCombined with 271 quality measuresSeparated into MIPS APM specific tables
MIPS APM Category WeightingsDifferent for different types of MIPS AMPsHarmonized. All MIPS APMS will have weightings of 50% Quality, 30% ACI and 20% AI
Virtual GroupNot authorizedAuthorized
MIPS Performance Category Weightings (No changes in 2018)Quality: 60%
ACI: 25%
IA: 15%
Cost: 0%
Quality: 60%
ACI: 25%
IA: 15%
Cost: 0%
Small Practice BonusNoneUp to 5 points (added to MIPS Final Score)
Complex Patients BonusNoneUp to 3 points (to Final MIPS Score) based on number of complex patients
Bonus for Using 2015 Edition of CEHRT exclusivelyNoneUp to 10 ACI points
MIPS Submission MechanismsAll measures in a category must be reported through the same mechanismAllow MIPS practices to submit
measures and activities through multiple submission mechanisms within a performance category
Facility-Based Measurement (MIPS Score)Not availalbeOptional facility-based scoring system based on the Hospital Value Based Purchasing Program
Minimum Quality Measure Scores3 points regardless of practice size and data completeness3 points for small practices regardless of data completeness. 1 point for large practices if data completeness requirement not met
Improvement Bonus for QualityNoneUp to 10 percentage points in the Quality Performance Category
Improvement Activities92 finalized for 2017Additional IAs proposed for 2018
CPC+ Model Included in Definition of Certified Patient-Centered Medical HomeNot applicableProposed for 2018
Immunization Registry Reporting10 ACI performance category pointsOptional. May also earn 5 points each for reporting any of the public health and clinical data registry as part of the performance score. Additional 5 points for reporting to an additional registry

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