Proposed QPP Changes: What You Need to Know

Thursday, July 26, 2018 | Ginger Biesbrock

As we find ourselves looking at another shift of reimbursement rules and regulations, many of us are having a hard time keeping up. And if you are like me, it’s not necessarily what you want to focus your time on. But alas, to a degree, we must. So I thought I would give you the ‘what you need to know’ for the proposed QPP changes for next year. Remember, they are proposed. We will have to wait and see what makes the cut; for now, it’s good to know what might be coming down the pike. (For those of you who want to read it for yourselves, the CMS fact sheet on the QPP can be found here.)

Thank you to Mark Domyhan of Pursuance Consulting for his summary of the larger document (below). I will start with the table that he put together. A major change in the overall strategy of MIPS is the drop in quality percentage and the increase in cost percentage. Our utilization continues to increase in dominance in this program. Yes – we are still tied to those QRURs.

Weighting and Payment (indicates 2018 figure)

For MIPS eligibility, there really are not changes for those of us who were eligible in the past. If you were eligible in past years, you will be eligible for this rendition as well. Unfortunately, based on the business that we do, many of our patients are Medicare so we are pretty much all in on this one. CMS continues to allow for virtual groups, but will provide organizations their TIN size to give you a better opportunity to decide the best option for reporting. In addition, there were several new providers added to the eligible clinician list, the only ones who may be pertinent to cardiovascular are social workers and possibly psychologists. The only placed I have seen these folks utilized is in chronic disease areas such as heart failure and transplant programs.

Category Changes

Cost – now worth 15% of the total score. Total per capita cost and Medicare Spending per Beneficiary measures are unchanged from previous. However, a new episode based measure is included for STEMI with PCI. In this procedural episode, if you render the PCI then it will be attributed to the you as the eligible clinician. For acute inpatient medical conditions, these episodes will be attributed to the eligible clinician who bills inpatient E/M claim lines during the trigger hospitalization under a TIN that renders at least 30% of the inpatient E/M claim lines for that hospitalization. This gets interesting for those of you in multi-specialty groups. It may no longer be the admitting provider who gets the attribution. The good news is that your cost performance category percent score will not account improvement until the 2022 performance period (payment in 2014). You should know where you stand now and going forward in order to know what needs to be improved upon and be prepared for 2022. It will be here before you know it.

Quality – now worth 45% of the total score. The major change in this category is that for those of you who have multiple options to report and choose the most advantageous option based on benchmarking, you will be able to submit the same measure through multiple collection types. However, scoring will be based on the data submission with the greatest number of measure achievement points. So, maybe a bit of a break; CMS will do the math for us and give us our best option.

Improvement Activities – still worth 15% of the total score. Major changes in this category include several new activity additions and modifications with one removal. For the cardiovascular world, the only new activities noted that may be of interest is relationship centered communication, patient medication risk education and completion of collaborative care management training program. The measure being removed is participation in population health research.

Promoting Interoperability – still worth 25% of the total score. The proposal for this year is that eligible clinicians must use a 2015 edition CEHRT. Four categories of measures require reporting and include e-prescribing, health information exchange, provider to patient exchange and public health/clinical data exchange. CMS appears to be making this category a bit less confusing by changing the base/performance/bonus score options to performance-based scoring at the individual measure-level. Sounds better as I never understood the math on the current interoperability measures.

So, this is where I feel the need to apologize to all of you. So many times, we try to get out in front of these proposed rules, we read, we summarize, we educate — then we find out that these proposed changes get ‘changed.’ It makes me chuckle at times and makes me cry at other times. We will continue to do our best to get you what you need to provide great patient care by keeping you empowered with good information, and what you need to do to survive in this ever-changing environment.



Illustration: Lee Sauer

About the Author
Ginger Biesbrock

Ginger Biesbrock, PA-C, MPH, MPAS, AACC, is Senior Vice President, MedAxiom Consulting. She is a respected executive, provider and teacher with 20+ years of experience in the health care industry with a concentration in clinical care and operations. Before joining MedAxiom Consulting, Ginger was Director of Operations at West Michigan Heart, a 39 Physician practice with 24 mid-level provider. At West Michigan Heart, Ginger oversaw all operations for ambulatory services, tertiary care and rural health practices. Prior to that Ginger was the COO of the Cardiovascular Group at Centra-Health.

Her areas of consulting expertise include APP Utilization, Care Team Optimization and Transitions of Care.

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