The Centers for Medicare & Medicaid Services (CMS) released its final rules outlining changes to the Quality Payment Program (QPP) and the Medicare Physician Fee Schedule (MPFS) for 2018. ASCO is still assessing the impact of both rules on the oncology community. However, provisions in the final rules, when taken together, could further reduce reimbursement that is already inadequate to ensure delivery of high-quality, high-value cancer care.
The society is disappointed that the QPP rule includes a provision that makes Medicare Part B drug reimbursement subject to Merit-Based Incentive Payment System (MIPS) adjustments. In comments on the proposed QPP rule, ASCO urged CMS to refrain from implementing such a policy at any point in time, asserting that it would seriously distort the magnitude of MIPS penalties and bonuses far beyond anything Congress intended when drafting the Medicare Access and CHIP Reauthorization Act (MACRA)—which established the QPP. ASCO’s data show that the median financial penalty for oncology practices under the proposal would range from 13.7% - 22.9%—well beyond the 4% penalty envisioned by Congress.
ASCO is concerned that in 2018, the MIPS Cost performance category will be weighted at 10% of total MIPS scores, and the Quality performance category will be weighted at 50% of total MIPS scores. CMS had proposed a weight of 0% for the Cost category, but finalized the weight at 10% with no risk adjustment in the methodology.
Disaster Relief, Flexible EHR Adoption, Other Changes
The society is encouraged that the QPP rule includes some relief for clinicians impacted by Hurricanes Irma, Harvey, and Maria, and other natural disasters. Specifically, the Quality, Advancing Care Information, and Improvement Activities performance categories will be weighted at 0% of these providers’ MIPS scores, and they will be awarded scores at the MIPS performance threshold (i.e., a neutral payment adjustment).
In 2018, CMS is also maintaining some flexibility in MIPS by allowing the use of 2014 or 2015 Edition Certified Electronic Health Record Technology (CEHRT) in the Advancing Care Information performance category. The agency also is lowering the low-volume practice threshold to clinicians or groups with $90,000 or less in Part B charges or 200 or fewer Medicare Part B beneficiaries, and adding 5 bonus points to the final MIPS scores of low-volume practices.
Additional changes to MIPS in 2018 include raising the MIPS performance threshold to 15 points (up from three points in 2017) and adding Virtual Groups as a participation option for MIPS.
2018 Medicare Physician Fee Schedule Update
ASCO’s initial review of the MPFS rule shows an estimated zero percent impact on the hematology/oncology community. It is important to note, however, that the actual impact on individual physician practices will depend on the mix of services provided.
Further changes to the MPFS in 2018 include:
- Separate billing codes and payments for newly approved biosimilars paid for under Medicare Part B. Effective January. 1, 2018, biosimilars with a common reference product will no longer be grouped into the same billing code.
- The new Appropriate Use Criteria (AUC) rule for diagnostic imaging will be deferred until 2020 to allow both clinicians and the agency time to prepare for this new program.
Both rules became available online on Nov. 2, and will be published in the Federal Register on Nov. 15. ASCO is conducting a detailed analysis and will submit comments to CMS during the open comment period. Stay tuned to ASCO in Action for more information when it becomes available.