“Regulatory wins” stemming from the fee schedule proposed rule listed on the dashboard include the delay in implementing the requirement that physicians consult appropriate use criteria (AUC) before ordering advanced diagnostic images, along with retroactive modification of legacy reporting programs such as Meaningful Use (MU) and the Physician Quality Reporting System (PQRS) to reduce penalties physicians may face in 2018 under the QPP’s Merit-based Incentive Payment System (MIPS).
Regulatory wins originating from the QPP proposed rule include proposals to increase the low-volume threshold exempting practices with few Medicare beneficiaries from the MIPS program and postponing a mandate for physicians to upgrade to 2015 edition certified electronic health records (EHRs).
A number of victories were also secured with respect to EHRs. For example, a process is being established for physicians to register complaints with an EHR product directly to the federal government for action, and EHRs must now include enhanced interoperability technology and support for apps.
The dashboard’s top asks for QPP regulatory relief include: simplifying MIPS scoring methodology, allowing specialty practices to qualify as APM medical homes and creating new exemptions and safe harbors from anti-kickback statutes to facilitate coordinated care.