Yesterday, the Centers for Medicare & Medicaid Services (CMS) released its proposed policies for Year 3 (2019) of the Quality Payment Program via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).  Below are some of the highlights for Year 3 of the Quality Payment Program:
  • Category weights of Total Composite Score:
    • Quality: 45%
    • Improvement Activities: 15%
    • Promoting Interoperability: 25% (Formerly called Advancing Care Information)
    • Cost: 15%
  • Performance Threshold is set at 30 points
  • Exceptional performance threshold set at 80 points
  • The maximum negative payment adjustment is -7 percent while positive payment adjustments can be up to 7% (but they are multiplied by a scaling factor to achieve budget neutrality)
  • Providing the option to use facility-based scoring for facility-based clinicians that doesn’t require data submission.
  • 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 proposed new 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.
  • Updating the MIPS APM measure sets that apply for purposes of the APM scoring standard.
  • Increasing flexibility for the All-Payer Combination Option and Other Payer Advanced APMs for non-Medicare payers to participate in the Quality Payment Program.
  • Updating the Advanced APM Certified EHR Technology (CEHRT) threshold so that an Advanced APM must require that at least 75% of eligible clinicians in each APM Entity use CEHRT.
  • Extending the 8% revenue-based nominal amount standard for Advanced APMs through performance year 2024.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Lauren Sloan, MHA, RD, LD
Director of Regulatory Affairs