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  • The Academy’s early analysis of the Quality Payment Program’s 2018 configuration is uncovering troubling changes. In finalizing the payment system for next year, the Centers for Medicare & Medicaid Services is reverting to requirements that will hurt ophthalmologists and other physicians who practice resource-intensive medicine.

    In our early analysis of the final rule CMS released Nov. 2, we uncovered major reversals from what CMS signaled in its proposed rule this summer. 

    Early analysis

    Despite our unwavering support for a zero-weight cost category in the Merit-Based Incentive Payment System, CMS has gone against its commitment to change the flawed cost calculations. Instead, the agency will now weight this category 10 percent of your score. 

    CMS will base cost on the previous flawed attribution and risk-adjustments used in the value-based modifier. This is a major issue for resource-intensive professions like ophthalmology. 

    What’s good

    Academy-sought exemptions exclude ophthalmologists from non-applicable measures

    CMS provides exclusions for two advancing care information base measures. The Academy was instrumental in securing the following exclusions.

    Additional exemptions for physicians

    CMS increased the low-volume threshold. This will enable more physicians to be completely excluded from MIPS reporting. CMS increased the low-volume threshold of allowed Part B charges to $90,000, from $30,000. The number of beneficiaries seen to qualify for an exemption doubled, to 200 or less. 

    Relief for small practices

    Small- and solo-practitioners (10 or fewer) will earn five bonus points toward the MIPS final scores. This applies to upwards of 80 percent of ophthalmologists. CMS continues to provide accommodations for small practices under the improvement activities category. Small-practice physicians would only have to do half as many activities as larger practices to get full category credit. 

    Acknowledging complexity of care

    CMS will award up to five bonus points on your MIPS final score for treatment of complex patients. 

    Catastrophic storm relief

    For clinicians affected by Hurricanes Irma, Harvey and Maria and other natural disasters, the agency will automatically weight the quality, advancing care information and improvement activities performance categories at zero percent of the MIPS final score. 

    EHR transition delay

    CMS finalized a delay in the transition to the 2015 standard for certified electronic health record technology. This was slated to take effect in 2018. The delay will last at least a year. 

    What’s next

    The Academy will mobilize this year to compel the agency to fix these unexpected changes. We will enlist Congress if necessary to secure the results that will make you successful in 2018. Stay tuned for comprehensive, ongoing analysis on and in Washington Report Express.

    Learn more

    Access the Academy’s broad array of resources for succeeding in the Quality Payment Program at