November 2017
Year 2 in the QPP: A Regulatory Update

On November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) Final Rule. The Final Rule contains notable changes that may affect smaller practices participating in the Merit-based Incentive Payment System (MIPS) and clinicians’ strategic participation in Alternative Payment Models (APMs).

QPP Background

Authorized by the bi-partisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation, the QPP consists of two pathways – MIPS and APMs:
  • MIPS requires certain clinicians to report specific quality and cost metrics and, as a result of such reporting and performance thereunder, clinicians may receive a positive or negative adjustment in their Medicare Part B reimbursement in future years. 
  • Under the QPP, clinicians may also participate in certain APMs that will exempt them from MIPS if, among other things, the APM involves financial risk and satisfies thresholds for Medicare patients and claims volume processed through the APM. For further background on MACRA and the QPP please reference our three-part overview, which can be found here

Highlights of the Final Rule

2017 was a transition year under the QPP. The Final Rule continues this transition during the QPP’s second performance year by addressing three major topics: changes to MIPS policies, changes to APM policies, and application of such policies in extreme and uncontrollable circumstances.

View the full eAlert here.