CMS Finalizes 2019 Quality Payment Program Rule

The Centers for Medicare and Medicaid Services (CMS) issued its policies for Year 3 (2019) of the Quality Payment Program via the Medicare Physician Fee Schedule (PFS) Final Rule. The provisions in the rule build on the foundation established in the first two years of the program, and are reflective of the feedback we received from many stakeholders.

Year 3 Final Rule Policy Highlights

In Year 3 of the Quality Payment Program, we are continuing to use the framework established by the Patients Over Paperwork initiative, implement meaningful measures, promote interoperability, support small and rural practices, reduce clinician burden, and improve patient outcomes.

Key policies for Year 3 include:

• Expanding the definition of a Merit-based Incentive Payment System (MIPS)-eligible clinician to include new clinician types, including physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutrition professionals.
• Adding a third element (Number of Covered Professional Services) to the low-volume threshold determination and providing an opt-in policy that offers eligible clinicians who meet or exceed one or two, but not all, elements of the low-volume threshold the ability to participate in MIPS.
• Applying facility-based scoring automatically for eligible facility-based clinicians without data submission requirements for individual clinicians and using group data submissions in the MIPS Promoting Interoperability or improvement activities categories to identify groups for facility-based scoring determinations.
• Modifying the MIPS Promoting Interoperability (formerly Advancing Care Information) performance category to support greater electronic health record (EHR) interoperability and patient access while aligning with the recent changes to the Promoting Interoperability Program requirements for hospitals.
• Moving clinicians to a smaller set of objectives and measures with scoring based on performance for the Promoting Interoperability performance category.
• Allowing small practices to submit quality data for covered professional services through the Medicare Part B claims submission type for the Quality performance category.
• Streamlining the definition of a MIPS comparable measure in both the Advanced Alternative Payment Models (APMs) criteria and Other Payer Advanced APM criteria to reduce confusion and burden amongst payers and eligible clinicians submitting payment arrangement information to CMS.
• Updating the MIPS APM measure sets that apply for purposes of the APM scoring standard.
• Updating the Advanced APM and Other Payer Advanced APM Certified EHR Technology (CEHRT) threshold so that these must require that at least 75% of eligible clinicians use CEHRT, and for Other Payer Advanced APMs, as of January 1, 2020, the number of eligible clinicians participating in the other payer arrangement who are using CEHRT must also be 75%.
• Extending the 8% revenue-based nominal amount standard for Advanced APMs and Other Payer Advanced APMs through performance year 2024.
• Finalizing proposals to implement the Medicare Advantage Qualifying Payment Arrangement Incentive Demonstration in 2018 under the authority in section 402(b) of the Social Security Amendments of 1967 (as amended).

For More Information

To learn more about the PFS Final Rule and the Year 3 Quality Payment Program policies, review the following resources:

• Press release – includes more details about today’s announcement
• Executive Summary – provides a high-level summary of the Quality Payment Program Year 3 final rule policies
• Fact Sheet – offers an overview of the policies for Year 3 (2019) and compares these policies to the current Year 2 (2018) requirements

CMS also encourages you to register for the Quality Payment Program Year 3 Final Rule Webinar on November 15 at 12:00 PM ET.