AAOS November 14, 2017
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Quality Payment Program and Physician Fee Schedule Finalized

On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2018. The calendar year (CY) 2018 PFS final rule is one of several final rules that reflect a broader Administration-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment, and innovation.

CMS also issued the final rule for the second year of the Quality Payment Program (calendar year 2018), as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). According to CMS, stakeholder feedback “is a very important part of the Quality Payment Program” and the agency has been using feedback to ensure that the program’s measures and activities are meaningful, that clinician burden is minimized, that care coordination is better, and that clinicians have a clear way to participate in Advanced Alternative Payment Models (APMs).

“In Year 2, we are keeping many of the flexibilities from the transition year to help clinicians get ready for Year 3,” the agency stated. “Since January 1, 2017, we’ve worked with more than 100 stakeholder organizations and over 47,000 people to get the word out about the Quality Payment Program, get feedback, and help make it easier for you to participate. We’ve also reviewed over 1,200 stakeholder comments and are finalizing many of the proposed policies from the calendar year (CY) 2018 Quality Payment Program proposed rule. Because we want to continue to receive your feedback, this is a final rule with comment period. The Quality Payment Program makes major changes to how Medicare pays clinicians. We’ve heard challenges and concerns from stakeholders, so we will keep: going slow while preparing clinicians for full implementation in year 3; providing more flexibility to help reduce your burden; and offering new incentives for participation.”

In comments to CMS on the proposed rule, AAOS applauded the increase in the low-volume threshold, noting that this will give clinicians in solo and small practices more time to prepare and meet the participation requirements. However, AAOS emphasized that there must still be more pathways for specialists to participate in the Quality Payment Program through the Advanced APM track. AAOS also commented on new proposals for virtual groups and the need for provision of clinician/practice data. Finally, the comments stressed that AAOS looks forward to engaging with CMS, “especially on developing outcome based measures for musculoskeletal care as well as on redesigning Medicare value-based payment models such that they are voluntary, physician-led, have accurate price setting, and provide access to data for all participants.”

To read the full AAOS comments on the Quality Payment Program Year 2, click here. For more information:

  • The Quality Payment Program final rule with comments can be downloaded from the Federal Register at: https://www.federalregister.gov/documents/2017/11/16/2017-24067/medicare-programs-cy-2018-updates-to-the-quality-payment-program-and-quality-payment-program-extreme.
  • For an overview of the final rule with comment, please visit: https://www.cms.gov/Medicare/Quality-Payment-Program/resource-library/QPP-Year-2-Final-Rule-Fact-Sheet.pdf. 
  • For an executive summary of the rule, visit: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/QPP-Year-2-Executive-Summary.pdf. 
  • Register here to join CMS on November 14 for a public webinar on the Quality Payment Program Year 2 Final Rule with comment.

Additionally, CMS recently launched the “Patients Over Paperwork” Initiative, a cross-cutting, collaborative process that evaluates and streamlines regulations with a goal to reduce unnecessary burden, increase efficiencies, and improve the beneficiary experience. According to CMS, this effort emphasizes a commitment to removing regulatory obstacles that get in the way of providers spending time with patients. The Medicare Physician Fee Schedule final rule includes the following as part of this initiative: (1) reducing reporting requirements and (2) removing downward payment adjustments based on performance for practices that meet minimum quality reporting requirements.

Read more about the Physician Fee Schedule online here: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-11-02.html.