Merit-Based Incentive Payment System (MIPS) 2017

Merit-Based Incentive Payment System (MIPS)  2017

 On April 27, 2016, the Department of Health and Human Services (HHS) released a proposed rule to implement provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  This proposed rule would replace the Sustainable Growth Rate (SGR) formula with a new Quality Payment Program for paying Medicare clinicians.  The deadline for the public to submit comments on the proposed rule was June 27th.  A final rule will be released by November 1, 2016.

UPDATE:  On September 8, 2016, CMS shared its plans for the timing of reporting for the first year of the new Quality Payment Program.  According to CMS, providers choosing one of these four options would avoid a negative payment adjustment in 2019:

Option 1:  "Test" the Quality Payment Program.  As long as providers submit some data in 2017, they could avoid a negative payment adjustment in 2019.

Option 2:  Participate for Part of the Calendar Year.  Providers could report for a reduced number of days after January 1, 2017, and could qualify for a "small positive payment adjustment".

Option 3:  Participate for the Full Calendar Year.  Providers who are ready to begin reporting on January 1, 2017, could report for the full calendar year and could qualify for a "modest positive payment adjustment".

Option 4:  Participate in an Advanced Alternative Payment Model (APM) in 2017.  If providers receive enough of their Medicare payments, or see enough of their Medicare patients, through an APM in 2017, they could qualify for incentive payments in 2019.

Key Highlights of the Proposed Rule:

Establishes a new Quality Payment Program with two payment models for providers to choose from:   the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs)

Consolidates the Physician Quality Reporting System (PQRS), the Value-Based Modifier Program and the Electronic Health Record (EHR) Meaningful Use program into a single program - MIPS

Provides “eligible clinicians” positive or negative payment adjustments under MIPS based on their performance in four categories:  Quality (formerly PQRS), Advancing Care Information

(formerly EHR Meaningful Use), Clinical Practice Improvement Activities and Cost

Provides incentive payments for participation in eligible APMs

Overview of the Proposed Rule

The new Quality Payment Program includes two paths for providers: The Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs).  Most Medicare clinicians will initially participate in the Quality Payment Program through MIPS which combines parts of the Physician Quality Reporting System (PQRS), the Value Modifier (VM or Value-based Payment Modifier), and the Medicare Electronic Health Record (EHR) incentive program into one single program.  CMS would begin measuring performance through MIPS in 2017 (reporting period), with payments based on those measures beginning in 2019.

MIPS Eligible Clinicians

MIPS would provide annual updates to Medicare “eligible clinicians” beginning in 2019 based on their performance in four categories:  Quality, Advancing Care Information, Clinical Practice Improvement Activities, and Cost.  

MIPS eligible clinicians will include physicians (MO/DO and DMD/DDS), PAs, nurse practitioners, clinical nurse specialists and nurse anesthetists during the first two years of the program. 

MIPS non-eligible clinicians, such as physical and occupational therapists, clinical social workers, and others would be permitted to voluntarily report under MIPS. 

The list of eligible clinicians could be expanded in the third year of the program and beyond.

Eligible clinicians can participate in MIPS as an individual or a group (defined by taxpayer identification number (TIN)).  A group would be measured as a group practice across all four MIPS performance categories.