2018 MACRA Proposed Rule Increases Low-Threshold Exclusions for MIPS

Added on Jul 21, 2017

2018 MACRA Proposed Rule Increases Low-Threshold Exclusions for MIPS

Physician practices with less than $90,000 in Medicare revenue or fewer than 200 unique Medicare patients per year would be exempt from having to comply with the Merit-based Incentive Payment System (MIPS) in 2018 under a proposed update to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) that was announced on June 20. Previously, the low-volume threshold exclusion for 2018 covered practices with less than $30,000 in Medicare revenue or fewer than 100 Medicare patients.

The Centers for Medicare & Medicaid Services (CMS) projects that 585,560 clinicians will fall under this exclusion and another 390,000 clinicians will fall under other exclusions, leaving just 37% of all Medicare Part B clinicians in MIPS in 2018.

The proposed rule, which is the first major update to MACRA under new federal health care leaders in the Trump administration, addresses participation requirements for 2018 and future years under MACRA’s MIPS and the Advanced Alternative Payment Model (Advanced APM) pathways.

Under the proposal, CMS will continue to treat the 2018 performance year as another transition year of the Quality Payment Program (QPP) and maintain program flexibility.

The proposed rule also outlines MIPS weighting for 2018 performance year/2020 payment year, as follows.

  • Maintain 60% weight for Quality.
  • Maintain 15% weight for Improvement Activities.
  • Maintain 25% weight for Advancing Care Information; clinicians can use 2014 or 2015 certified electronic health record technology (CEHRT), with a bonus for using 2015 CEHRT.
  • Maintain zero weight for the cost performance category; however, CMS seeks comments on introducing this category at 10%. CMS continues to develop and test episode-based measures which will be introduced over time.
Additional highlights of the proposed rule include the following.

  • Implementation of virtual groups, allowing small groups and solo practitioners under two or more taxpayer identification numbers to participate in MIPS as a single group for both 2018 and 2019. Technical assistance will be made available to these practices.
  • Implementation of facility-based measures in MIPS to allow clinicians to be assessed based on their facility’s performance.
  • Continued recognition of qualified clinical data registries such as the NCDR PINNACLE Registry and the Diabetes Collaborative Registry as MIPS data reporting options.
  • Maintenance of the nominal risk and qualifying participant thresholds for the Advanced APM pathway.
  • Implementation of the “All-Payer Combination Option” for the Advanced APM pathway starting in the 2019 performance year.​
Comments on the proposed rule, which can be read in full here, are due Aug. 30.