To date, we know that the 2018 performance year for the Quality Payment Program (QPP) will bring some relief to eligible clinicians in small practices and rural areas in the way of a higher low-volume performance threshold, Virtual Groups and allowing for additional submission mechanisms. The Centers for Medicare and Medicaid Services (CMS) has also proposed that additional Improvement Activities be added to the list so that practices have more to choose from.
The good news is that there will be no change in the number of activities required of small practices (defined as 15 or fewer eligible clinicians), practices in rural areas or geographic HPSAs and non-patient facing clinicians. This is great news, especially for those practices who already added two activities during the 2017 Performance year. If you did so, then just keep on doing what you’re doing and make sure to document the activities in case of an audit. To clarify, if you added telehealth and chronic care management services during 2017, all you will need to do for 2018 is continue offering those services and document them correctly. The exact requirement is two medium-weighted activities or one heavy-weighted activity to fulfill the category and earn the full amount of points.
If you are a larger practice, defined as more than 15 eligible clinicians, you will need to earn the full 40 points by having some combination of medium-weighted activities and heavy-weighted activities. Remember, medium activities are worth 10 points and heavy activities are worth 20. This means you could add 4 medium-weighted or 2 heavy-weighted or a combination of the two. Whatever makes sense for your practice and adds up to the full 40 points.
The Improvement Activities category will continue to count for 15% of your Total Composite Performance Score (TCPS). CMS has also proposed that simple attestation of the Improvement Activities is all that will be required for reporting purposes. More good news! Additionally, those who report as a group will be allowed to attest positively, as long as one eligible clinician in the group has performed the Improvement Activity. For instance, if you are a group practice of 12 eligible clinicians, and you added telehealth as one of your Improvement Activities, only one of the 12 clinicians must perform at least one telehealth visit with one Medicare Beneficiary for the entire group to attest positively. CMS couldn’t have made it easier for you.
Though the new Improvement Activities have not been added to the QPP website yet, keep your eyes out for the upcoming list and for changes that could be made to the current list.