Proposed 2018 QPP Rule Adds Flexibility, but Questions on Medicare Part B Drugs Provision Remain

June 21, 2017

The Centers for Medicare & Medicaid Services (CMS) released its proposed rule outlining changes to the Quality Payment Program (QPP) for 2018. The proposal became available on June 20 and is scheduled to be published in the Federal Register on June 30.

ASCO is encouraged by the rule’s increased flexibility for QPP-participating providers and practices, which includes an extended transition period through the end of 2018. ASCO is still analyzing the more than 1,000-page rule, but key provisions for the oncology community in the Merit-Based Incentive Payment System (MIPS)—one of QPP’s two tracks—in 2018 include the following:

  • The option to “pick your pace” will be extended through all of 2018, so that physicians can avoid a financial penalty in 2020 by reporting a limited amount of 2018 quality data in 2019.
  • Virtual groups will be implemented.
  • The low-volume practice threshold will increase to less than or equal to $90,000 in Medicare Part B charges (up from $30,000 in 2017) or less than or equal to 200 Medicare Part B patients (up from 100 patients in 2017).
  • Practices will be allowed to continuing using 2014 Edition CEHRT (Certified Electronic Health Record Technology), while being incentivized to use 2015 edition CEHRT.
  • Bonus points will be added for caring for complex patients or using 2015 Edition CEHRT exclusively.
  • Bonus points will be added for small practices (15 or fewer clinicians).
  • Some new Improvement Activities (a MIPS scoring category) will be tied to appropriate use criteria.
  • Improvement in the quality performance category will be included in the quality performance score.
  • Facility-based clinicians will have the option to use facility-based scoring.
  • Resource use (cost) data will be collected, but as in 2017, it will not affect MIPS scores or physician reimbursement in 2020.

Regarding Advanced Alternative Payment Models (APMs), the other QPP track, the CMS proposal would keep many of the current provisions in place for the second transition year in 2018. The proposed changes and updates include:

  • Extending the revenue-based nominal amount standard, which was previously finalized through performance year 2018, for two additional years (through performance year 2020). This standard allows an APM to meet the financial risk criterion to qualify as an Advanced APM if participants are required to bear total risk of at least 8 percent of their Medicare Parts A and B revenue.
  • Changing the nominal amount standard for Medical Home Models so that the minimum required amount of total risk increases more slowly.
  • Giving more detail about how the All-Payer Combination Option will be implemented. This option allows clinicians to become Qualifying APM Participants (QPs) through a combination of Medicare participation in Advanced APMs and participation in Other Payer Advanced APMs. This option will be available beginning in performance year 2019.
  • Giving more detail on how eligible clinicians participating in selected APMs will be assessed under the APM scoring standard. This special standard reduces burden for certain APMs (MIPS-APMs) participants who do not qualify as QPs, and are therefore subject to MIPS.

ASCO’s analysis of the proposed rule will also focus on a provision that could make certain Medicare Part B drug reimbursements subject to MIPS adjustments. ASCO will address this and all relevant provisions in its comments to CMS on the proposed rule before the agency's open comment period closes August 18.

ASCO’s QPP toolkit has the latest resources to help practices prepare for full implementation of the Medicare Access and CHIP Reauthorization Act (MACRA), which established the program. ASCO in Action features breaking MACRA updates and all the latest cancer policy news.