The Colorado Medical Society is part of a coalition of organizations representing physicians and other providers that is working with the Department of Health Care Policy and Financing (HCPF) to address problems associated with the system conversion earlier this year. To prepare for meetings with the Department staff we need your assistance in identifying the top issues you are currently facing as a result of the Medicaid system conversion. Please email your response to marilyn_rissmiller@cms.org no later than Friday, Nov. 10.

The Centers for Medicare and Medicaid Services recently issued the final rule and comment period for the 2018 (year 2) Quality Payment Program. QPP Year 2 will feature many of the flexibilities as the transition year, including: 

• Going slow while preparing clinicians for full implementation in year 3.
• Providing additional flexibility to reduce clinician burden.
• Offering new participation incentives.

Combined, the regulations are approximately 3,000 pages in length. Here are the highlights. 
 

Patients Over Paperwork Initiative

The federal CMS launched a new initiative for evaluating and streamlining regulations with goals to reduce unnecessary burden, increase efficiencies, and improve the beneficiary experience. To further this initiative, the year 2 final rule features the following: 

• Excludes individual MIPS eligible clinicians or groups with less than or equal to $90,000 in Part B allowed charges; or less than or equal to 200 Part B beneficiaries. 
• Addresses extreme and uncontrollable circumstances, such as hurricanes and other natural disasters, for both the transition year and the 2018 MIPS performance period.  
• Includes a virtual group participation option. 
• Makes it easier for clinicians to qualify for incentive payments by participating in Advanced APMs that begin or end mid-year. 

MIPS

• Maintains many of the transition year policies with some minor changes. 
• Provides more options for small practices (15 or fewer clinicians). 
• Continues gradual implementation approach to prepare clinicians for full implementation in year 3. 
• Includes policies for addressing extreme and uncontrollable circumstances for both the transition year and 2018 MIPS performance year. 
• Implements provisions in the 21st Century Cures Act, some of which will apply to the MIPS transition year. 
• Introduces the Virtual Groups participation option 

For more information 

See the federal CMS' QPP Year 2 Fact Sheet for full details, including APM participation highlights and directions for submitting comments to the agency.

On Oct. 18, the Centers for Medicare and Medicaid Services opened the 30-Day Preview Period for the 2016 performance information targeted to be publicly reported on Physician Compare starting in December 2017. The preview was scheduled to end on Nov. 17 at 8 p.m. ET. Due to a technical issue preventing the data from properly displaying in the preview portal, the Provider Quality Information Portal (PQIP), all data were not viewable for the first week of preview. This display issue has now been resolved and the federal CMS is extending preview through Friday, Dec. 1 at 8 p.m. ET to provide more time for clinicians and groups to preview their performance data as a result of this technical issue.

For more information about preview and the measures available for preview, visit the Physician Compare Initiative page. For assistance with accessing PQIP, or obtaining your EIDM user role, contact the QualityNet Help Desk at 866-288-8912 or qnetsupport@hcqis.org. If you have any questions about Physician Compare, public reporting, or the preview period, please contact PhysicianCompare@Westat.com.

The Centers for Medicare and Medicaid Services recently released the Proposed Rule guidelines for a third way to participate in the QPP MIPS track starting in 2018. If physicians are thinking of pursuing this participation option, they must apply before Dec. 1, 2017. If you have questions or need help, contact Courtnay Ryan at cryan@telligen.com.

As proposed in the 2018 Quality Payment Program proposed rule, solo practitioners and groups can choose to participate in the Merit-based Incentive Payment System (MIPS) as a virtual group for the 2018 performance period. To form a virtual group for 2018, solo practitioners and groups need to engage in an election process. For the 2018 MIPS performance period, the election period for virtual groups to make an election is from Oct. 11, 2017 to Dec. 1, 2017.

What is a Virtual Group?
The federal CMS has proposed a virtual group to be a combination of two or more Taxpayer Identification Numbers (TINs) made up of:

• A solo practitioner who's eligible to participate in MIPS and bills under a TIN with no other National Provider Identifiers (NPIs) billing under the TIN, OR
• A group with 10 or fewer eligible clinicians (at least one must be eligible for MIPS) that joins with at least one other solo practitioner or group for a performance period of a year.

How do I form a Virtual Group?
To form a virtual group, CMS has proposed a two-stage virtual group election process:

• Stage 1 (optional): Solo practitioners and groups with 10 or fewer eligible clinicians may contact their designated Technical Assistance representative or the Quality Payment Program Service Center to determine if they are eligible to join or form a virtual group.
• Stage 2: For groups that choose not to participate in Stage 1 of the election process, the federal CMS will determine if they are eligible in Stage 2. During Stage 2, the virtual group must name an official representative who will submit their election to the agency via email to MIPS_VirtualGroups@cms.hhs.gov by Dec. 1, 2017.

The election would include:

1. A written formal agreement between each of the virtual group members; and
2. Information about the TIN and NPI associated with the virtual group representative's contact information.

For more information about joining or forming virtual groups, see the Virtual Groups Toolkit.

Need help with the election process?
Contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222). You can also contact your local support organization for support.