CMS Proposes Changes to 2016 PQRS and VBPM Reporting Requirements and Penalties Affecting 2018 Payment Seeks Comments on Additional Policies to Relieve Regulatory Burden

2018 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS) PROPOSED RULE RELEASED

CMS Proposes Changes to 2016 PQRS and VBPM Reporting Requirements and Penalties Affecting 2018 Payment Seeks Comments on Additional Policies to Relieve Regulatory Burden

Proposed 2018 Conversion Factor $35.99

Late this afternoon, CMS released the CY2018 MPFS Proposed Rule, which will be published in the Federal Register on July 21, 2017. There is a 60 day comment period for this proposed rule. ASCRS will be submitting comments.

2017 MPFS Conversion Factor

The CY 2018 proposed MPFS conversion factor is $35.99, which reflects a budget neutrality adjustment of -0.03%, a misvalued code recapture amount of -.019%,and the 0.5%update factor specified under MACRA.

Key Policy Changes Regarding 2016 PQRS and VBPM Reporting Requirements and Penalties Affecting 2018 Payment

Following ASCRS and medical community advocacy, CMS is proposing to modify the 2016 reporting requirements for PQRS to assist practices avoid the 2% PQRS penalty and the 2% or 4% (depending on practice size) penalty under the Value-based Payment Modifier (VBPM). 

CMS is proposing to change the 2016 (for 2018 payment) PQRS program policy that requires reporting of 9 measures across 3 National Quality Strategy domains to only require reporting of 6 measures to avoid the PQRS penalty.

For the VBPM, CMS proposes to:

  • Reduce the automatic downward payment adjustment for not meeting minimum quality reporting requirements from -4% to -2% for groups of ten or more clinicians; and from -2% to -1% for physician and non-physician solo practitioners and groups of two to nine clinicians;
     
  • Hold harmless all physician groups and solo practitioners who met minimum quality reporting requirements from downward payment adjustments for performance under quality-tiering for the last year of the program; and
     
  • Align the maximum upward adjustment amount to 2 times the adjustment factor for all physician groups and solo practitioners.

Additional Opportunities for Regulatory Relief

CMS continues its efforts to provide regulatory relief for physician practices in this proposed rule. They are including a request for information for feedback on "positive solutions to better achieve transparency, flexibility, program simplification, and innovation." ASCRS will be providing comments on steps CMS can take to achieve this goal. CMS expects to use the information collected to develop policies related to the fee schedule in future years.

Potentially Misvalued Codes

CMS continues its statutorily-mandated effort to identify and re-value potentially misvalued codes. The 2018 MPFS proposed rule includes hundreds of additional potentially misvalued codes. ASCRS will be working with the ophthalmic community to respond to any potential re-valuations of ophthalmic codes.

Evaluation and Management (E/M) Comment Solicitation

CMS has heard from stakeholders that documentation related to E/M codes may be out of date and requirements may present additional administrative burden on physicians. CMS is seeking comments on specific changes they should undertake to update the guidelines, to reduce the associated burden, and to better align E/M coding and documentation with the current practice of medicine.

Additional information will be detailed in upcoming editions of Washington Watch Weekly. For questions, please contact Allison Madson, manager of regulatory affairs, at 703-591-2220 or amadson@ascrs.org.