But some observers point to potential pitfalls for practices if they don't get on the onramp early in the program.
The main issue is that after 2019, there will be no increase to the physician fee schedule for providers that are not participating in MIPS — even those excluded due to low volume. "This means that by raising the low-volume threshold, CMS has removed the opportunity to earn any level of increase in the foreseeable future," explains Jeanne Chamberlin, a practice management consultant with MSOC Health in Chapel Hill, N.C. She notes that the proposed rule for 2018 said that CMS would "consider" allowing those that meet one but not all of the low-volume exclusion criteria to participate on an optional basis, but the final rule stated that the agency decided to seek additional comments on the best approach of implementing a low-volume threshold opt-in policy.
Another lesson from the first year of the program, Chamberlin says, is that small practices need to rely heavily on their EHRs — for both the ACI and Quality areas, but many EHR vendors are struggling to catch up with CMS on the MIPS program. This is especially the case with having more than nine electronic clinical quality measures available and keeping those up to date. The biggest compliance problem in 2017 has been how to collect the quality data, she says. "Even if they have an EHR, practices often don't know how they are supposed to enter the data in order to have the system count it properly – this is a training issue and raises the 'too many clicks' mantra of most clinicians," she says.
Looking Ahead to 2018
So what are some new elements of the QPP that could catch practices by surprise in 2018?
In 2017, CMS weighted the Resource Use or Cost category at zero because it wanted more time to create better measures. In the proposed rule for 2018, it proposed to weight the category at zero again before deciding to allocate 10 percent to Cost for next year. Practices will need time to understand how the Cost category impacts them before it ramps up to 30 percent of the total MIPS score in the 2019 reporting period.
Michael Abrams, co-founder and managing partner of St. Louis-based consulting firm Numerof & Associates, expects physician practices to struggle with the Cost category. "Providers are having difficulty getting their arms around the current categories, and Cost is a brand new one that they have to accept CMS's data for," he says. "For these other categories, the physicians are providing the data, and they probably feel that they have more control over that because the data is a reflection of what they doing clinically. Cost, however, is something that comes from CMS, and they are going to have to accept that on faith, and that is going to make it that much more difficult."