National Council Submits Comments on New Medicare Payment Rule
Last week, the National Council submitted comments to the Centers for Medicare and Medicaid (CMS) on a proposed rule that will make changes to Medicare’s Quality Payment Program (QPP) in 2018. The QPP, which went into effect on January 1, 2017, includes two paths to payment for eligible clinicians who bill Medicare using the Physician Fee Schedule: The Merit-based Incentive Payment System (MIPS), and Advanced Alternative Payment Models (APMs). By moving from volume-based payment to payment for quality and value, both systems change the way behavioral health providers are reimbursed under Medicare Part B.
The 2018 proposed rule included several changes to QPP that will benefit behavioral health providers, including increasing the QPP low-volume threshold, which will exempt solo practitioners and smaller Medicare practices from participation. The 2017 low-volume threshold exempts individual clinicians and clinician groups that serve 100 or fewer Medicare beneficiaries, or bill Medicare $30,000 or less per year. The National Council expressed its support for the proposed increase in this threshold, which would exempt individual clinicians and groups who serve fewer than 200 Medicare beneficiaries or charge Medicare less than or equal to $90,000 in 2018.
The National Council also praised CMS’s proposal to award bonus points for small practices (defined as fewer than 15 clinicians), rural practices, clinicians who practice in a medically underserved area, and practices that serve high-risk populations. The National Council was also pleased to note that the proposed rule applies an adjustment of 1 to 3 bonus points by adding the average Hierarchical Conditions Category (HCC) risk score to eligible clinicians’ final MIPS score, which will benefit behavioral health providers who serve a disproportionately high risk patient population.
The National Council also expressed support for the establishment of “virtual” clinician groups, defined as a combination of two or more Tax Identification Numbers (TINs) composed of a solo practitioner or a group with fewer than 10 eligible clinicians. The National Council believes that the ability to form virtual groups will enable solo behavioral health providers and those in small practices to share resources, and will reduce their reporting burden. In their first year, the proposed rule states that virtual groups will not be limited in size, and may define their own composition, without restrictions on geography or specialty.
The National Council also recommended modifications to each MIPS performance category, including the addition of behavioral health-related measures. While the National Council strongly supported CMS’s expansion of the Mental/Behavioral Health specialty measure set from 10 measures to 25 measures in last year’s final rule, we encouraged CMS to consider expanding the measure set by adding the following behavioral health quality measures in 2018:
- Follow-up after Discharge from the Emergency Department for Mental Health or Alcohol or Other Drug Dependence (National Quality Forum (NQF) #2605)
- Alcohol Screening and Follow-up for People with Serious Mental Illness (NQF #2599)
- Tobacco Use Screening and Follow-up for People with Serious Mental Illness or Alcohol or Other Drug Dependence (NQF #2600)
- Body Mass Index Screening and Follow-Up for People with Serious Mental Illness (NQF #2601)
- Controlling High Blood Pressure for People with Serious Mental Illness (NQF #2602)
- LDL Screening for people with schizophrenia or bipolar disorder who are using antipsychotic medications (NQF 1927)
- Diabetes screening for people with schizophrenia or bipolar disorder who are using antipsychotic medications (NQF 1932)
- Adherence to mood stabilizers or people with bipolar I disorder (NQF 1880)
- Use of multiple concurrent antipsychotics (HEDIS 2016)
- Follow-Up After Emergency Department (ED) Visit for Mental Illness (HEDIS 2017)
- Follow-Up After Emergency Department Visit for Alcohol and Other Drug Dependence (HEDIS 2017)