MACRA is quickly approaching year 2. CMS recently released their 2018 Proposed Rule, and there are some significant changes everyone should be aware of. Rather than wading through the 1,058 pages of the Proposed Rule, join CareOptimize for a look at the most important takeaways. In less than 30 minutes, you'll learn: Are any of your clinicians now exempt? What is a Virtual Group, and will it save you money? Are your practice's priorities aligned with the newly weighted categories? How can the Proposed Rule increase your 2018 bonus?

2. Proposed MIPS Rule
Restates MIPS is a benefit to practices
with greater flexibility for participation.

3. Major Aim
“We’ve heard the concerns that too
many quality programs, technology
requirements, and measures get
between the doctor and the patient.
By proposing this rule, we aim to
improve Medicare by helping doctors
and clinicians concentrate on caring for
their patients rather than filling out
paperwork.”
Seema Verma, CMS Adminstrator

4. Exemptions Increased
63%
of all Medicare
clinicians will be
exempt from MIPS in
2018.

5. Remember:
There will be more
money for those
who do full MIPS
and qualify for
exceptional
performance bonus.

6. Increased Medicare Threshold
Projected:
New rule will exclude
585,560 clinicians
Other exclusions affect
390,000 clinicians
Will leave
37% eligible
CMS has increased
the low-volume
threshold
exclusion.
Individuals or groups
< $90,000 in Part B
charges
Or
200 Part B patients

7. Regulatory Burdens Eased
Aim:
To reduce the regulatory burden on physicians while
continuing the transition to value-based reimbursement
• The impact of MACRA will be mitigated for many smaller
practices, despite the increased complexity of the program.
• However, there will be a smaller pool of penalty dollars to fund
the incentives for high performers, which could discourage
participation across the market by practices of all sizes.
Several wins for small practices

8. Use of 2015 Certified EHR
Optional for MIPS in 2018
CMS also proposed a 90-day reporting period for ACI
for both 2018 and 2019. Providers can delay moving
to the 2015 Edition until October 2019.
NOTE: Providers who do use the
2015 Edition would receive a 10%
ACI bonus.

9. Still required for certain APM
participants in 2018
• Those in the CPC+ program are still required to
use 2015 CEHRT in 2018 for a full year, starting
1/1/2018.
• No change for participants in the Medicaid MU
program, but that might change if CMS aligns the
MIPS ACI and MU requirements.
Use of 2015 Certified EHR

10. Hospital-based Physicians
• Can be assessed on quality and
cost in the context of the facilities
where they work.
• Can submit their facility's
inpatient value-based score to
help calculate an individual score.

11. Pick Your Pace
Important Revisions
• Scoring for the quality category retains the three-point floor
imposed in 2017 (out of 10 possible points).
• Overall MIPS performance threshold, or benchmark, will increase
from three to fifteen (out of a possible 100 points).
Will Continue in 2018

12. Cost Category in 2018
MIPS clinicians should continue to gather knowledge and develop a
strategy for future success in the cost category.
0%of the overall MIPS score in 2018
(30% of the overall MIPS score in 2020.)

13. Quality Category in 2018
Quality Category
will account
for
60%

14. Submission Mechanism
CMS will allow multiple submission mechanisms within the
ACI, Quality, and Improvement Activities categories.
One submission
mechanism per
performance category
• EHR
• Claims
• Registry
• etc.
Measures and
activities can be
submitted through
multiple submission
mechanisms within a
performance
category.
2017 2018

15. Providers can Choose
Providers can now
participate in MIPS as
• Individuals
• Groups
• Virtual groups*
*Virtual Groups
Solo practitioners and groups with 10 or fewer eligible clinicians, who join
together “virtually” to participate.
Providers can elect to participate in a virtual group prior to the start of the
2018 performance period and are not restricted by size or geography.

16. Hardship Exception
Starting in 2018 –
• Practices with 15 or fewer clinicians are offered a
“significant hardship” exception to opt out of MIPS
ACI.
• ACI performance category is reweighted to zero,
shifting the ACI scoring weight of 25% to the quality
category.
• A clinician could apply for the exception if “there are
overwhelming barriers that prevent the MIPS-eligible
clinician from complying with the requirements” for
ACI (details still pending).

17. Advanced APMs
Regulations would
largely remain unchanged in 2018.
• Exemption: CPC+ participants with more than 50 clinicians in
their parent organization can remain as an Advanced APM in
2018 and beyond.
• For the first time, CMS outlined critical details regarding the
2019 implementation of the All-Payer Combination Option.

18. Shawna.Matonis@careoptimize.com
www.careoptimize.com
855.937.8754