Feedback on the proposed final rule for CMS’ 2018 Quality Payment Program (QPP), created under MACRA, was due last week. However, influencers in the urgent care space have been mostly mum on the subject because, with a few exceptions, much of the what’s included in the proposed final rule does not have a major impact on urgent care practices.

Back in October 2016, when the initial final rule that implemented MACRA was released, the Urgent Care Association of America (UCAOA) did provide feedback on the Meaningful Use requirements, now known as Advancing Care Information (ACI) under the MIPS track. In a joint letter with 15 other organizations to Secretary of Health and Human Services Tom Price, UCAOA stated that eligible providers should not be required to use EHR technology certified to the 2015 edition because the timeline was “unnecessarily aggressive,” even with a 90-day EHR performance period in 2018. The letter also requested the implementation of Stage 3 of the Meaningful Use program and the stage 3-like measures in the MIPS program be delayed indefinitely.

This feedback was taken into account, and the proposed final rule for the 2018 QPP states that eligible clinicians can choose whether they use EHR technology certified to the 2014 or 2015 editions. As far as the required Meaningful Use measures, eligible providers will report on measures based on the certification year of their EHR technology. That’s good news for most urgent care practices, but this may cause some challenges for eligible providers who work in hospital-affiliated urgent cares.

According to The Advisory Board, this is the first time CMS might not align certified EHR technology requirements between quality reporting programs – namely, the 2018 Inpatient Prospective Payment System (IPPS) and the 2018 QPP. Under the 2018 IPPS proposed rule released by CMS in April 2017, hospitals participating in the Inpatient Quality Reporting and Meaningful Use and eligible providers who report Medicaid Meaningful Use are required to use an EHR technology certified for 2015 in program year 2018. That doesn’t impact most urgent care practices, but health systems managing both hospital and ambulatory quality programs would have to monitor two very different sets of requirements. And, given the time crunch, if a hospital decides to only upgrade EHR technology in the hospital setting and not within its urgent care practices, that could cause a great deal of confusion for eligible providers working between settings.

We expect CMS to release the final 2018 QPP rule on November 1, 2017, with the possibility of more changes to come based on the feedback CMS received from other specialties. The American Academy of Family Physicians, for example, “adamantly demand” an opt-in option to MIPS for practices that are otherwise excluded based on the low-volume Medicare thresholds in the proposed final rule. However, the American Hospital Association (AHA) supports CMS’ proposal to increase the Medicare threshold. The AHA also urged CMS to align requirements for eligible providers in the ACI performance category with the requirements for eligible hospitals and critical access hospitals participating in the Medicare and Medicaid EHR Incentive programs.

Whatever the outcome of the 2018 QPP final rule, urgent care providers should not wait until November to act. October 2, 2017, marks the beginning of the last 90-day reporting period in 2017, so urgent care providers should know whether they’re eligible and how they’re going to participate before the beginning of October. If you’re not sure what to do, we outline the steps we recommend you should take in our article “How does MACRA Impact Your Urgent Care Practice?”

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