CMS Releases 2020 Proposed Rule for the Quality Payment Program

Today, the Centers for Medicare & Medicaid Services (CMS) released its proposed policies for the 2020 performance year of the Quality Payment Program via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

Key proposals for 2020 performance year of the Quality Payment Program include:

• Increasing the performance threshold from 30 points to 45 points
• Revising category weights for Quality (decreases from 45% to 40%) and Cost (increases from 15% to 20%)
• Increasing the data completeness threshold for the quality data that clinicians submit
• Increasing the threshold for clinicians who complete or participate in the Improvement Activity for group reporting
• Updating requirements for Qualified Clinical Data Registry (QCDR) measures and the services that third-party intermediaries must provide (beginning with the 2021 performance period)
• Revising the specifications for the Total Per Capita Cost (TPCC) and Medicare Spending Per Beneficiary Clinician (MSPB Clinician) measures

CMS is committed to ongoing transformation of the Merit-based Incentive Payment System (MIPS), which will allow for: more streamlined and cohesive reporting; enhanced and timely feedback loops; and pathways of integrated measures that are meaningful to all clinicians from specialties to primary care and to patients. The new MIPS Value Pathways (MVPs) will encourage transition to Advanced Alternative Payment Models (APMs) and promote value by focusing on quality, interoperability and cost.

Based on stakeholder comments, we are also looking for feedback on how MIPS can be further transformed to reduce burden, increase value, and by focusing participation around specific measures/activities or public health priorities that are more meaningful to clinician’s practices and specialties. The proposed MVP framework for achieving this transformation is outlined in the NPRM for comment.

Highlights of the MVP proposals include:

• The creation of “bundles” or “tracks” of care called MVPs that connect measures and activities across the four MIPS performance categories, which incorporates a foundation leveraging Promoting Interoperability measures and a set of administrative claims-based quality measures that focus on population health and public health priorities that are meaningful to clinicians. Some examples of potential MVPs include Major Surgery and Diabetes Prevention and Treatment.
• A clinician would participate via one MVP, that would include measures and activities for the Quality, Improvement Activities, Cost and Promoting Interoperability performance categories that would be cross-cutting and aligned within that MVP
• We envision, in the future, MVPs will be available for all clinicians and will be co-developed in partnership with specialty societies or other organizations to ensure we’re creating MVPs that are relevant and meaningful for clinicians and their patients.

Submit Comments

CMS is seeking comment on a variety of proposals in the NPRM, including feedback on the proposed new MVPs. Comments are due by September 27, 2019.

You must officially submit your comments in one of the following ways:

• Electronically, through Regulations.gov
• Regular mail
• Express or overnight mail
• By hand or courier

For More Information

To learn more about the PFS NPRM and the Quality Payment Program proposals, review the following resources:

• Press release – Provides more details about today’s announcement
• Fact sheet – Offers an overview of the QPP proposed policies for 2020 (year 4) and compares these policies to the current 2019 (year 3) requirements
• MIPS Value Pathways Diagram - This zip file contains three visual diagrams of the proposed MVP framework, including an MVP example for Diabetes Prevention and Treatment and an example for Major Surgery.

To learn more about the Quality Payment Program, visit: https://qpp.cms.gov.