November 3, 2017

Rules affect 2018, 2020 payment.

CMS released two rules yesterday, November 2, which will directly affect podiatrists' payments in 2018 (CY 2018 Medicare Physician Fee Schedule) and 2020 (CY 2018 Updates to the Quality Payment Program). APMA is currently reviewing both rules in depth and will provide additional updates soon, but has found the following updates to be pertinent to our members: 

CY 2018 Updates to the Quality Program—MIPS Year 2

• Clinicians with less than $90,000 Medicare Part B allowable charges or fewer than 200 Part B beneficiaries are excluded from the 2018 MIPS reporting period.
• The threshold to avoid a penalty in 2020 is now 15 MIPS points, versus three MIPS points for 2019. The exceptional performance threshold remains at 70 MIPS points.
• The 2018 Reporting Periods are as follows:
  • 12 months—Cost and Quality performance categories
  • 90 days—ACI and CPIA performance categories
• The Cost performance category will count now for 10 percent of MIPS score, which will be calculated by Medicare Spending per Beneficiary (MSPB) and total per capita cost measures. There is no active reporting for this category, which CMS will calculate.
• 2014 and 2015 CEHRT are allowed, but bonus ACI points will be available only to physicians using 2015 CEHRT.
• Practices with 15 or fewer clinicians are exempt from the ACI category. Those practices will then have their Quality performance category reweighted to 75 percent of the MIPS composite score.
• Clinicians affected by Hurricanes Harvey, Irma, or Maria who do not submit 2017 MIPS data will not have a negative adjustment in 2019. Additionally, physicians affected by these hurricanes may file a hardship exemption application for Quality, ACI, and CPIA categories for the 2018 performance period.
• Clinicians can now participate in Virtual Groups.

CMS has provided a fact sheet on the new rule. Members can read APMA's comments to the proposed rule at www.apma.org/CommentLetters, and we are reviewing the final rule to determine what most affects our membership so we can submit additional comments.

CY 2018 Medicare Physician Fee Schedule (MPFS)

• Podiatrists on average will experience a 1-percent increase in allowed charges across their book of business. The overall update to payments under the Medicare Physician Fee Schedule based on the finalized CY 2018 rates will be +0.41 percent.
• CMS agrees with APMA's comments that the E/M documentation guidelines need to be streamlined. It will address comments and stakeholder concerns in future rulemaking.
• CMS will finalize the start date for the Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging. It will begin with an educational and operations testing year in 2020, which means physicians would be required to start using AUCs and reporting this information on their claims.
• As part of its "Patients over Paperwork" initiative, the 2018 MPFS included reducing reporting requirements and removing downward payment adjustments based on performance for practices that meet minimum quality reporting requirements.

APMA will be reviewing this final rule in more detail, and will provide a summary of its impacts to our members in the near future. 

If you have questions or concerns, please contact the Health Policy and Practice Department.