The Centers for Medicare and Medicaid Services (CMS) Oct. 14 published a final rule with comment period on the Medicare Access CHIP Reauthorization Act (MACRA) physician payment system. The new payment system, also referred to as the Quality Payment Program (QPP), involves two payment options for physicians: the Merit-based Incentive Payment System (MIPS) and the Alterative Payment Models (APMs). CMS would begin to measure performance for physicians and other clinicians through MIPs in calendar year (CY) 2017 with payment adjustments based on their performance beginning in CY 2019.
In efforts to provide maximum flexibility within the QPP, CMS established a less stringent reporting timeline and four reporting options for eligible clinicians (ECs). ECs will have the option to collect performance data anytime between Jan. 1, 2017, to Oct. 2, 2017, and the data must be submitted by March 31, 2018, in order to earn a potential positive payment adjustment. CMS estimates that over 90 percent of MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment in 2019. Clinicians have the following four options during the first year of participation, known as the “transition year:”
-
Report MIPS for a full 90-day period, or the full year to maximize the chances to quality for a positive adjustment. Exceptional performers may receive an additional positive adjustment (requires achieving a final score of 70 or higher);
-
Report MIPS for less than the full year but for a full 90-day period and report more than one quality measure, more than one improvement activity, or more than the required measured in advancing care information to avoid a negative adjustment and possibly receive a positive adjustment;
-
Report one quality measure, one clinical improvement activity, or report the required measures of advancing care information to avoid a negative adjustment. If ECs do not report a quality measure or a clinical improvement activity, then they will receive a negative 4 percent payment adjustment; or
-
Participate in Advanced APMs and qualify for a 5 percent bonus incentive payment.
Furthermore, MIPS participants will have the option to report on all four performance categories either individually or as a group. Under MIPS, the performance categories for the first year are weighted as follows:
-
Quality (60 percent): Number of measures required to report vary based on reporting option
-
Advancing Care Information (ACI) (25 percent): Must fulfill the required measures for a minimum of 90 days and can report additional measures for bonus credit—however are not required to submit measures if they do not apply to you
-
Clinical Practice Improvement Activity (CPIA) (15 percent): Number of activities varies by group size but must be reported for a minimum of 90 days
-
Resource Use (0 percent): No data submission required but CMS will calculate performance on certain cost measures and give this information to clinicians in performance feedback.
The definition of “more than nominal financial risk,” a statutory requirement for Advanced APMs, has been reduced from what was proposed; the new standard is open for comment. To qualify under the Advanced APM payment route and receive the 5 percent incentive payments, ECs must receive 25 percent of Medicare Part B Payments through an Advanced APM or treat 20 percent of Medicare patients through an Advanced APM. If thresholds are unmet, then the EC must plan to submit MIPS data to avoid a downward payment adjustment. The agency estimates that 70,000-120,000 clinicians will be Qualified Participants based on participation in Advanced APMs.
The AAMC will be hosting a webinar on the final rule and will be providing additional resources to assist members in transitioning to the new payment system. CMS has made additional information available on its website.