CMS Finalizes 2018 Quality Payment Program Rule

On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) released its 2018 Quality Payment Program Rule. The final rule affects physician anesthesiologists and practices who participate in either the Merit-based Incentive Payment System (MIPS) or in Advanced Alternative Payment Models (APMs). ASA submitted comments on the rule in August.

The final rule includes several elements that are beneficial to physician anesthesiologists and their practices. ASA advocacy efforts resulted in expanded opportunities for physician anesthesiologists to report quality measures and improvement activities in 2018.

• CMS finalized MIPS 463: Prevention of Post-Operative Vomiting (POV) - Combination Therapy (Pediatrics).
• CMS also finalized participation in a Perioperative Surgical Home (PSH) as a Medium weighted improvement activity. ASA is excited about this recognition of PSH as it will allow the work of PSH sites to be rewarded as early as next year in the MIPS program.
• CMS also provided stability regarding renewal of Qualified Clinical Data Registries (QCDRs).

Of note, CMS changed the minimum threshold for eligibility from excluding an individual or group that has ≤ $30,000 in Part B allowed charges or ≤ 100 Part B beneficiaries to excluding individuals or groups if they have ≤ $90,000 in Part B allowed charges or ≤ 200 Part B beneficiaries.

Structurally, however, the rule includes significant changes that may impact a physician anesthesiologist’s or their practice’s ability to participate and be accurately scored under MIPS. ASA is concerned about CMS’s decision to implement the MIPS Cost Component. CMS finalized that the MIPS Cost Component for application in calendar year 2018 (payment year 2020). The Cost Component will be based in part upon the Medicare Spending per Beneficiary and total per capita cost measures. This has traditionally been difficult for physician anesthesiologists to participate.

ASA physician leaders and staff continue to review the QPP Final Rule and will develop educational and implementation materials for members and their practices in the upcoming weeks.

Read the QPP Final Rule here.

Read the QPP Final Rule Summary here.

For general information on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), please visit the ,a href="http://www.asahq.org/macra">ASA MACRA webpage.