Compliance Tips: Quality Payment Program Year 3 Final Rule

CMS released the Quality Payment Program Year 3 Final Rule on November 1^st. The rule included the removal of 26 Quality Measures, the addition of 10 new Quality measures, and significant changes to the Promoting Interoperability category of the program. Nextech will be releasing more information on these changes in the near future, including a video outlining the changes with tips to prepare for the coming year. Until then, here are a few steps to get you started.

Direct Messaging

First, use your direct messaging application to exchange Care Coordination Documents (CCDs) with your referring and co-managing providers. The Promoting Interoperability category scoring has changed, but sending CCDA documents electronically and receiving and incorporating CCDA documents electronically is still a requirement.

Quality Measures

Next, evaluate the Quality measures that you will use in 2019 before the performance year begins. The Quality measures must be reported for a full year again in 2019 and 4 measures that affect our clients were removed from the program:

a. #88: Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy - Registry and EHR Direct
b. #140: Age-Related Macular Degeneration (AMD): Counseling on Antioxidant Supplement - Registry only
c. #224: Melanoma: Avoidance of Overutilization of Imaging Studies - Registry only
d. #373: Hypertension: Improvement in Blood Pressure - Registry and EHR Direct

In the new scoring structure, registry reporting is required to revive any points in the Promoting Interoperabilty category for the 2019 performance period. If you are not reporting to a clinical registry for year 2 of the QPP, you will need to in year 3 to get any points in the Promoting Interoperability category. There are exclusions that may apply to your practice related to reporting to a second registry.

Penalties

Please note that the threshold to avoid a penalty will increase to 30 points in year 3 and the penalty for failing to report or attaining 0 points is -7%.

Next Step

Now is the time to assess your performance in year 2 and address how you will meet the requirements for year 3 of the program.

Nextech is currently working to develop the 2 new Promoting Interoperability measures related to Opioids that were announced in the rule and will communicate with clients when these measures are available. Both of these measures are bonus measures for 2019 and will require only 1 patient in the numerator to earn the 5 points per measure bonus score. 

Watch for further information related to the Quality Payment Program Year 3 on the Client Community Portal or on the blog section of the website to be alerted when new compliance materials are available.