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 Requirement | MACRA 2017 | MACRA 2018 (Proposed) |
|---|---|---|
| MIPS Eligibility (Part B Payment) | More than $30,000 per year | More than $90,000 per year |
| MIPS Eligibility (Part B eligible patients seen per year) | More than 100 | More than 200 |
| Quality Measure Data Reporting Period | 90 days or more (to achieve the highest possible score) | 365 days |
| Use of 2015 Edition CEHRT (Stage 3) | Required conversion in 2018 | Relaxed conversion in 2018, 2014 edition remains optional |
| MIPS Performance Threshold | 3 points | 15 points |
| MIPS APM Participant Snapshot Dates | March 31, June 30 and August 31 | March 31, June 30 August 31, and December 31 |
| MIPS APM Measures | Combined with 271 quality measures | Separated into MIPS APM specific tables |
| MIPS APM Category Weightings | Different for different types of MIPS AMPs | Harmonized. All MIPS APMS will have weightings of 50% Quality, 30% ACI and 20% AI |
| Virtual Group | Not authorized | Authorized |
| 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 Bonus | None | Up to 5 points (added to MIPS Final Score) |
| Complex Patients Bonus | None | Up to 3 points (to Final MIPS Score) based on number of complex patients |
| Bonus for Using 2015 Edition of CEHRT exclusively | None | Up to 10 ACI points |
| MIPS Submission Mechanisms | All measures in a category must be reported through the same mechanism | Allow MIPS practices to submit measures and activities through multiple submission mechanisms within a performance category |
| Facility-Based Measurement (MIPS Score) | Not availalbe | Optional facility-based scoring system based on the Hospital Value Based Purchasing Program |
| Minimum Quality Measure Scores | 3 points regardless of practice size and data completeness | 3 points for small practices regardless of data completeness. 1 point for large practices if data completeness requirement not met |
| Improvement Bonus for Quality | None | Up to 10 percentage points in the Quality Performance Category |
| Improvement Activities | 92 finalized for 2017 | Additional IAs proposed for 2018 |
| CPC+ Model Included in Definition of Certified Patient-Centered Medical Home | Not applicable | Proposed for 2018 |
| Immunization Registry Reporting | 10 ACI performance category points | Optional. 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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