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Legacy Reporting Programs

The previous quality reporting programs, which CMS terms as "legacy" programs, Physician Quality Reporting System (PQRS), Medicare Electronic Health Record Incentive Program, and the Value-Based Payment Modifier (VBPM), have been phased out and replaced with the Quality Reporting Program (QPP), which includes the Merit-based Incentive Payment System (MIPS). The last performance period for the legacy programs was 2016 which impact 2018 payment.

Please Note: Key Policy Changes Regarding 2016 PQRS and VBPM Reporting Requirements and Penalties Affecting 2018 Payment

Following ASCRS and medical community advocacy, CMS modified the 2016 reporting requirements for PQRS to help practices avoid the 2% PQRS penalty and the 2% or 4% (depending on practice size) penalty under the Value-based Payment Modifier (VBPM).

CMS finalized changes to the 2016 (for 2018 payment) PQRS program policy that requires reporting of 9 measures across 3 National Quality Strategy domains to only require reporting of 6 measures with no domain or cross-cutting measure requirement to avoid the PQRS penalty.

For the VBPM, CMS will:

  • Reduce the automatic downward payment adjustment for not meeting minimum quality reporting requirements from -4% to -2% for groups of ten or more clinicians; and from -2% to -1% for physician and non-physician solo practitioners and groups of two to nine clinicians;
  • Hold harmless all physician groups and solo practitioners who met minimum quality reporting requirements from downward payment adjustments for performance under quality-tiering for the last year of the program; and
  • Align the maximum upward adjustment amount to 2 times the adjustment factor for all physician groups and solo practitioners.

If you have any questions please contact Allison Madson, manager of regulatory affairs, at or 703-591-2220.

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