CMS Relents, Will Reduce 2017 MIPS Reporting Burden
You can expect CMS to soften the impact of its Merit-Based Incentive Payment System (MIPS) for 2017. There will be four options given to providers for complying with MIPS on Jan. 1, 2017, which is when performance-measuring begins for 2019, the first MIPS payment year.
Each option offers varying levels of difficulty, so providers can choose how much effort to invest based on their readiness. The agency made the announcement via a blog post authored by CMS Acting Administrator Andy Slavitt.
Details are sketchy, but these options are expected to be fleshed out in the final rule for the Medicare Access and CHIP Reauthorization Act (MACRA). The MIPS program consolidates all of Medicare’s existing major pay-for-performance incentive programs into a single entity, and MIPS is a core component of the MACRA law.
Here are the four options outlined by Slavitt:
- First option: Report some, not all, MIPS data for 2017. This option should have the least impact on practices, and will result in no MIPS payment adjustment in 2019 (e.g. avoid any negative adjustment, but get no positive adjustment either). As long as you report some data for some period of time in 2017, you won’t be dinged in 2019.
- Second option: Report all MIPS data, but only for part of 2017. This option raises the stakes slightly by requiring full MIPS participation for part of the year. Slavitt did not provide a specific timeframe for “part of the year.” Choosing this option will result in a “small positive payment adjustment” for 2019, though how much was not specified.
- Third option: Report all MIPS data for all of 2017. This option is basically what all providers would be required to do under the MACRA proposed rule. This will result in a “modest positive payment adjustment” for 2019, though again no value was provided for “moderate.”
- Fourth option: Participate in an Advanced Alternative Payment Model (APM). Assuming your practice participates fully in an APM, such as an Accountable Care Organization, the Medicare Shared Savings Program (tracks 2 or 3), or any other pay-for-performance model in 2017, you’ll get a 5% positive payment update in 2019. The catch is that only APMs recognized as “advanced” by CMS will be eligible. A full list of advanced APMs and the criteria for an APM to be recognized as advanced is available on the agency’s website.
The problem is that there are no numbers or values for any of the terms that Slavitt uses in his blog post, says Brad Coffey, government affairs manager for the Association of Orthopaedic Executives (AAOE) in Indianapolis. “All we have are what’s in the blog post. I think we’ll see actual numbers in the final rule.” The lack of specificity means you won’t know exactly how much data you need to report, or for how many days, or how much of a positive adjustment you’ll get for each option yet.
Without that information, practices won’t know if it’s worth their effort to participate partially with MIPS in 2017, Coffey says. “The only thing this really solves for is giving us more time to prepare. Ultimately, if the structure for MIPS in the coming years is still going to be similar to what’s in the proposed rule, we’ll still be concerned.”
Look for the four-option provision to appear with specific details in the MACRA final rule, expected in early November.
— Grant Huang, CPC, CPMA (firstname.lastname@example.org). The author is Director of Content at DoctorsManagement.