2019 QPP Final Rule Summary

The 2019 Quality Payment Program (QPP) Final Rule was released yesterday. For those of you who don’t have time to read the final rule’s 2,400 pages, CORHIO’s Transformation Support Services Manager Lauren O’Kipney has created the following summary.

Newly eligible clinician types:

• Physical Therapist, Occupational Therapist, Speech-Language Pathologist, Audiologist, Psychologist, Registered dietitian

Opt-In Options: If you meet one of the criteria below, you have the option to opt in (if you meet all three criteria, you are required to report and if you do not meet any of the three criteria, you do not have the option to opt in). Note – There are two determination periods, and you must meet an opt in option within both periods.

• >=$90K allowed charges
• >=200 enrolled beneficiaries
• >=200 covered professional services

Virtual Groups – each individual or group TIN can join a virtual group if each individual or group TIN can join if they meet at least one of the opt in options (note - only one determination period considered – October 1 2017-September 30 2018)

• Must elect to do this by December 31

Quality becomes worth 45% of final score– you can report via multiple submission mechanisms (example, 2 measures via claims and 4 via registry)

• Claims measures may now be reported as group if under 15 eligible clinicians within the group (TIN)

Promoting Interoperability

• 2015 CEHRT REQUIRED
• Overhaul of measure, no more base measures (except security risk analysis), all measures based on performance

Cost Category

• Worth 15% or score
• Measures: Total Per Capita Cost, Medicare Spending Per Beneficiary and 8 episode-based measures (as applicable)
• Threshold to Avoid Penalty – increased to 30 points (from 15 in 2018)
• Possible +/- 7% adjustment

Note: MIPS Program Year 2018 – no changes were made. Reminder: no opt-in options,  possible +/- 5% adjustment rate, 15 points to avoid penalty, quality measure reporting remains as full year (only one submission method allowed**

A few notes on the fee schedule changes for 2019 from the final rule:

• Levels 2-4, will now be paid the same, less documentation needed
  • Level 5 still increased rate, less documentation needed
  • Thankfully did NOT pass - E/M codes billed on the same day as procedures would be reduced by 50% (so happy commenters got this thrown out)
  • More options for billing tele-health/e-visits

CMS Fact Sheet for the Final Rule: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Year-3-Final-Rule-overview-fact-sheet.pdf