The Centers for Medicare & Medicaid Services today issued a proposed rule updating the requirements of the quality payment program for physicians and eligible clinicians mandated by the Medicare Access and CHIP Reauthorization Act of 2015. The QPP includes two tracks – the default Merit-based Incentive Payment System and advanced alternative payment models. The rule proposes key policies for the QPP’s 2018 performance period, which will affect clinician payment in 2020. Among other policies, CMS proposes to increase the MIPS’s low-volume threshold, thereby excluding more than 585,000 eligible clinicians from the program. CMS also proposes to implement a MIPS reporting option that allows hospital-based clinicians to use their hospital’s value-based purchasing measure results in the MIPS program. CMS also proposes to continue using a 90-day reporting period for the advancing care information category in 2018, and to allow clinicians to use the 2014 edition of certified electronic health records for the ACI category. In addition, CMS proposes policies related to clinicians’ ability to earn incentives for participation in advanced APMs. This includes more detail regarding the all-payer option that, beginning in 2019, will allow clinicians to qualify for advanced APM incentives based on combined participation in alternative payment arrangements with Medicare and non-Medicare payers (including Medicare Advantage, Medicaid and private payers). “Today’s proposed rule continues the incremental, flexible implementation approach called for by hospitals, health systems and the more than 500,000 employed and contracted physicians with whom they partner to deliver care,” AHA Executive Vice President Tom Nickels said in a statement. “We are encouraged by CMS’s proposal for a facility-based clinician reporting option that may promote better alignment and collaboration on efforts to improve quality among hospitals and clinicians. We also applaud CMS’s proposal to provide much-needed relief from unrealistic, unfunded mandates for EHR capabilities by extending the use of modified stage 2 meaningful use requirements through 2018. We will encourage CMS to provide the same relief to hospitals. We also encourage CMS to provide additional opportunities for clinicians to earn incentives for partnering with hospitals to provide better quality, more efficient care through advanced alternative payment models.”

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