This Month, CMS released the 2018 MACRA final rule. You can read our full summary of the rule here. CMS is accepting comments on the rule through January 1, providing another opportunity to seek further improvements for practices like yours. NCQA will be stressing two issues in our comments. You might want to include them in your comments, too.

Reducing Burden: Advancing Care Information & Our Recognized Practices

The first is providing Advancing Care Information (ACI) auto-credit for Patient-Centered Medical Homes (PCMH) and Patient-Centered Specialty Practices (PCSP). As you may know, MACRA already offers MIPS Improvement Activity auto-credit to NCQA-Recognized PCMHs and PCSPs. Clinicians not in recognized PCMHs and PCSPs must report on individual Improvement Activities to earn this credit.

CMS is giving ACI auto-credit for Improvement Activities that involve health IT in ways that meet ACI measures. However, CMS is not yet giving PCMHs and PCSPs ACI auto-credit, even though they clearly meet enough ACI measures. NCQA provided a cross-walk of how PCMH and PCSP standards align with ACI measures in our 2018 proposed rule comments, and will do so again in commenting on the final rule.

ACI auto-credit would mean PCMHs & PCSPs get both the 15% Improvement Activities score and the 25% ACI score – a total of 40%! That’s why we encourage you to also submit comments urging CMS to give PCMHs and PCSPs ACI auto-credit.

Involving Smaller Practices in Virtual Groups

The second issue we’ll stress in our comments: letting practices below the low-volume threshold join Virtual Groups. Virtual Groups let practices with 10 or fewer clinicians join together to have robust numbers for valid measurement. They can be a first step toward working together across settings to improve quality and eventually join Alternative Payment Models.

However, CMS is defining clinicians in practices below the low-volume threshold ($90,000 in Medicare revenue or 200 Medicare patients) as ineligible for MIPS, and the law says clinicians must be eligible for MIPS to join Virtual Groups. We think practices that are ready and willing to report and participate in a value-based payment system should be able to. That way, they can prepare themselves to join an APM or other payment models in the future.

CMS could easily fix this by changing the low-volume definition to say such clinicians are MIPS ineligible “unless they join a Virtual Group.” This simple change would allow many more small practices to join Virtual Groups and hasten their ability to improve quality, as Congress intended.

Once You’re Comments Are Ready…

You can submit your comments on the MACRA 2018 final rule here.