On November 1, 2018, the Centers for Medicare and Medicaid Services (CMS) issued its final rule
for Year 3 of the Quality Payment Program (QPP). This year, CMS combined the final QPP rule with the final 2019 Physician Fee Schedule.
AANEM reviewed all 2,379 pages of the rule and while several of AANEM’s comments and suggestions were adopted in the final rule for the Physician Fee Schedule, including proposed changes to the E/M codes, most of AANEM’s concerns about the QPP went largely unheeded. The QPP will continue to be a challenging program for specialists and subspecialists, especially EDX and NM physicians, to participate in, but AANEM is hopeful that through its continued work with CMS and policymakers, we will be able to decrease the burdens associated with the QPP and increase the efficacy of the program.
In 2019, the third year of the QPP, CMS is raising the expectations for participation as well as penalties for lack of participation. All physicians who bill Medicare Part B and do not qualify for an exemption are required to participate in the program or face a payment penalty of 7% (up from 5% in 2018) of their Medicare Part B payments. To find out whether you are required to participate, you may look up your NPI on the Centers for Medicare and Medicaid Services’ (CMS) QPP website
Changes to the QPP for Performance Year 2019 include:
- Low-Volume Threshold and Opt-In Policy. CMS added a third criterion for physicians to qualify for the low-volume threshold—providing 200 or fewer covered professional services to Part B patients. CMS also adopted a new policy that allows physicians to opt-in to participate in MIPS or create virtual groups if they meet or exceed one or two but not all the low-volume threshold elements (i.e., have more than $90,000 in Part B allowed charges for covered professional services, provide care to more than 200 Medicare beneficiaries, or provide more than 200 covered professional services under the Physician Fee Schedule).
- Performance Threshold. CMS increased the 2019 performance threshold for determining bonuses or penalties in 2021 to 30 points (up from 15) and the additional exceptional performance threshold to 75 points (up from 70).
- MIPS Expanded to New Clinician Types. CMS expanded the MIPS-eligible clinician definition to include physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians or nutrition professionals.
- Facility-Based Scoring Option. 2019 is the first year physicians may be scored for purposes of the MIPS quality and cost performance categories based on their attributed hospital’s performance in the Hospital Value-Based Purchasing Program so long as they furnish 75% or more of their covered services in a hospital setting.
There were also several change to the 4 performance categories within the QPP, many of which are unlikely to affect AANEM members. However, a couple of changes that are likely to affect AANEM members include:
- Required use of only 2015 Certified Electronic Health Record Technology (CEHRT) for the Promoting Interoperability (PI) Category (f/k/a Advancing Care Information Category); and
- The ability for most clinicians to use multiple data collection/reporting methods for the Quality Category (i.e., clinicians can report measures using a combination of methods, such as claims, EHR, registry, etc.) and for clinicians to report the same measure via multiple methods, with the clinician only receiving a score for the method they performed best on.
AANEM is currently updating its MACRA & The Quality Payment Program: A Guide for AANEM Members to provide a detailed explanation of the QPP along with the 2019 changes. Updates should be completed by the end of December 2018.
If you have any questions or concerns related to the Guide or the QPP in general, please contact the AANEM Policy department