On February 8, 2018, President Donald Trump signed the Bipartisan Budget Act of 2018 marking changes to the Merit-based Incentive Payment System(MIPS) track of the Quality Payment Program (QPP).

Per the Bipartisan Budget Act of 2018, clinicians should expect changes to the MIPS “transition” years.

Transition Years 2018-2021

• 2018-2021 are now considered “transition” years
• The Cost category weight will range 10%-30% as determined by the Health and Human Services (HHS) Secretary of State annually
• The MIPS performance threshold will continue to gradually increase annually
• There are no longer improvement bonuses for the Cost category
• MIPS payment adjustments and low-volume exclusions will be based solely on Medicare Part B “covered professional services” (excluding items and Part B drugs)

Post-Transition now starts in 2022

• Cost category will be weighted at 30% beginning 2022
• MIPS performance threshold must be the mean or median of national historic MIPS scores

While the Bipartisan Budget Act of 2018 is bringing changes to MIPS, some requirements are expected to remain the same.

Remaining the same

• Schedule of maximum MIPS penalties for low performance or non-participation will not change:
  • -5% for 2018 performance year/2020 payment year
  • -7% for 2019 performance year/2021 payment year
  • -9% for 2020 performance year/2022 payment year and beyond
• CMS will continue to publicize MIPS participation data on the Physician Compare website, as well as assign star ratings.
  • The first of publication for MIPS participation will occur in Q4 2018.
• The compliance and reporting requirements for all four performance categories will not change; however, thresholds for performance will continue to increase.

QPP is here to stay

CMS is driving performance improvement by increasing thresholds annually. Due to low-volume exclusions, the number of clinicians and groups who are not eligible to participate are expected to increase. Likewise, payment adjustments – both negative and positive – are expected to reduce.

It is important to remember that your reputation is still at stake. CMS promises to share participation or lack thereof publicly. This data has the potential to impact your reputation, rapport with patients and colleagues, and even contracts and fee schedules with commercial payers. Clinicians and groups that are proactive with setting organizational goals for participation annually, implementing workflows to support success and approach the program proactively will reap the benefits. It is not a time to be reactive.