Radiology Considerations Under Year Two of the QPP
CMS is calling on physicians to ramp up their QPP participation in 2018.
Next year, 2018, is the second transitional year for the Quality Payment Program (QPP) before full implementation in 2019. CMS still offers the “pick your pace” option for level of participation.
However, CMS intends for physicians to ramp up their participation in 2018, a calling that has relevant and immediate implications for radiology — and one that provides a glimpse into the future of the QPP.
The more common payment pathway for radiology remains the Merit-Based Incentive Payment System (MIPS), which is basically fee-for-service with quality payment adjustments. Under MIPS, a final score between 0 and 100 is assigned to physicians based on performance in the following categories: quality, cost, advancing care information (ACI), and improvement activities (IA). CMS determines a threshold score, at which a neutral adjustment occurs. Scores above the threshold earn a bonus, and those below it are assigned a penalty. In 2017, the threshold score is three points. In 2018, it increases to 15. This increase illustrates CMS’ intent that physicians increase their engagement in the program.
Non-patient-facing (NPF) physicians have less reporting requirements, such as a complete ACI exemption, and necessary reporting of only half the IAs. So correctly identifying our NPF status is important. For 2018, the criteria to be considered as an NPF physician are unchanged: less than 100 patient encounters per year. For group reporting, if 75 percent or more of the group members meet the individual definition of NPF, the entire group is considered NPF. CMS will update the list of patient-encounter codes later this year, with the possibility that more radiology services could be categorized as patient encounters. Practices should watch these updates closely so they know their status.
The 2018 ramp-up especially affects the quality category. For NPF physicians, quality accounts for a sizable 85 percent of our score (IAs account for 15 percent, and cost is not being scored in 2018). In 2017, with a threshold score of three, we essentially could report one quality measure and earn the required three points. With a 2018 threshold score of 15, the number of reported measures increases. This score could be composed of more measures in the quality category or measures in other categories, such as IAs. In 2018, quality reporting must occur over the entire calendar year, an increase from the 90-day requirement in 2017.
For next year, there remain about 90 approved IAs, although some updates occurred. The ACR has published a summary of the activities (available at bit.ly/TwoQPP). Practices will want to review this list and adjust accordingly. As in 2017, a simple attestation regarding 2018 participation will suffice. One of the new IAs relates to the use of clinical decision support and appropriate use criteria in the ordering of advanced diagnostic imaging studies, which could help practices engage their referring physicians. Remember that a mandate for the use of clinical decision support and appropriate use criteria begins in 2019. Participation in R-SCAN™ satisfies seven medium-weight activities, ensuring maximal points in the IA category. This collaborative action plan brings radiologists and referring clinicians together to improve imaging appropriateness based on a growing list of imaging Choosing Wisely topics. Learn more at rscan.org.
Small practices, defined as those with fewer than 15 physicians, receive several favorable accommodations for 2018. These practices receive more points for quality measures, as well as bonus points to their final score. Only half the number of IAs are required, the same as NPF physicians. Practices with fewer than 10 members can join virtual groups, thereby joining other small practices to participate in MIPS as a group. Small practices will want to weigh the benefits of virtual group participation (such as greater resources for reporting) compared with the benefits of reporting as a small practice (such as reporting allowances and bonus points).
What does the future hold for radiology beyond 2018? Since CMS intends for the QPP to be fully implemented in 2019, our reporting requirements will continue to increase. In addition, the cost category will be scored for the first time in 2019. The many allowances and exemptions that we will have in 2018 may not last forever. Since we likely will have to embrace ACI in the future, the call to explore and embrace certified EHR technology at the facility, radiologist, and vendor levels is heightened. One thing seems certain: The time for radiologists to ramp up their participation in the QPP is now.
By Ezequiel Silva III, MD, FACR, Chair