News & Insights

Comments on QPP Year 3 Proposed Final Rule Encouraged

July 19, 2018

Comments on QPP Year 3 Proposed Final Rule Encouraged

In July, the Centers for Medicare & Medicaid Services (CMS) released its QPP Year 3 Proposed Final Rule. Providers are encouraged to submit their comments and suggestions before September 10, 2018, as CMS will consider all comments prior to publishing the Final Rule. Provider input can significantly impact the future of the QPP program.  

Comments must be submitted in one of the following three ways:

1. Electronically at www.regulations.gov. Follow the “Submit a comment” instructions.

2. By regular mail to the following address only:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1693-P
P.O. Box 8016
Baltimore, MD 21244-8016

3. By express or overnight mail to the following address only:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1693-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

Comments submitted via fax will not be accepted.

Listed below are a few of the proposed changes to begin January 1, 2019:  

  • The non-participation penalty will increase to 7%
  • Eligible clinicians will include Physical Therapists, Occupational Therapists, Clinical Social Workers and Clinical Psychologists
  • The Low Volume Threshold will remain at $90,000 and 200 Medicare Part B patients or 200 covered professional services
  • In some situations, exempt clinicians may have the ability to opt-in
  • Quality will count for 45%, Improvement Activities (IA) 15%, Promoting Interoperability (PI) 25% and Cost will count for 15% of the total MIPS score
  • Quality and Cost will be evaluated on a full-year reporting period. PI and IA will remain at 90 days.
  • Data in any one performance category may be submitted to CMS via different submission methods
  • Only 2015 Certified EHR Technology will be acceptable for PI
  • The minimum score to avoid a penalty will increase from 15 to 30 points

The following resources are also available from CMS:

  • Press release – provides more details about the announcement
  • Fact sheet – offers an overview of the proposed policies for 2019 (Year 3) and compares these policies to the current 2018 (Year 2) requirements

LAMMICO will provide more information regarding the 2019 performance year when the rule is finalized, but remember, right now we can still help you to avoid 5% penalty in 2020!  

Contact LAMMICO Practice Management Specialist, Natalie B Cohen, MBA, MHA at 504.841.2727 or nochen@lammico.com for more information or consultation.

This is not legal or financial advice, and is not intended to substitute for individualized business or financial judgment. It does not dictate exclusive methods, and is not applicable to all circumstances.

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