MIPS Sees Changes In Its Final Rule
CMS has chosen to compromise with providers in its final rule for the Merit-Based Incentive Payment System (MIPS), not only offering easier reporting during the first two years of the program, but also reducing the amount of measures required for MIPS components.
CMS has stated that 2017 will be a transition year, during which providers and the agency itself will “build capabilities to report and gain experience with the program.” Let’s take a deeper look at how the MIPS final rule differs from the proposed rule.
First, remember that MIPS consolidates four existing Medicare quality programs into a single new program, and each of the four programs have been renamed as MIPS performance categories. They are Quality (formerly PQRS), Advancing Care Information (formerly meaningful use), Clinical Practice Improvement Activities (same name), and Cost (formerly Value-based Payment Modifier). Each category is weighted a different amount but all contribute towards a single MIPS “composite” score which is a value from 1 to 100.
- Cost category won’t count in 2017. The cost performance category, previously slated to be worth 10% of your MIPS score, now won’t be counted during the 2017 reporting period for MIPS, a major change in the final rule that skews the other three categories. Now the quality performance category will be worth 60% of your MIPS score, while advancing care information will be worth 25% and clinical practice improvement 15%. The cost category will still be calculated by CMS based on your claims data and will count toward your MIPS score in years 2018 and beyond.
- Meaningful use reporting requires less measures. You will only need to report a total of five measures under the advancing care information performance category which replaces meaningful use. This is down from 11 measures in the proposed rule, and while it represents a concession by CMS, it may not help you as much as you think. Many practices who are able to report all 11 measures because they’ve done it under the old meaningful use program will have no problem continuing to do so, which means they’ll be likely to get higher scores and more MIPS money than practices that just choose to do the easier five-measure minimum.
- Payments and bonuses for 2019. The maximum Medicare Part B payment adjustment, positive or negative, will still be 4% in 2019 based on 2017 reporting. There is a separate $500 million budget set aside in the MIPS program to reward providers who participate and score exceptionally well, with CMS setting a threshold score to determine who gets bonus payments from this budget. In the final rule, CMS has set a MIPS score of 70 or higher as its threshold for a share of that $500 million pot. The MIPS baseline score will be 3 points, which means any provider scoring 3 points or higher will avoid a negative adjustment. This is a very low baseline, which means only providers who completely avoid MIPS will go below 3 points and receive a negative payment adjustment. Instead, most providers will receive a neutral adjustment and some will receive a positive adjustment.
- Advanced Alternative Payment Models (APMs) still in progress. Another way out of MIPS reporting is participation in Alternative Payment Models (APMs) that are determined to be “advanced” by CMS. This includes participating in certain Accountable Care Organizations (ACOs) and Medicare Shared Savings Programs (MSSPs), so long as they are certified “advanced” by CMS.
More APM details to come
Providers who participate in an advanced APM are able to avoid MIPS reporting entirely because CMS exempts them. They also receive a regular positive payment update of 5% to their Medicare fee schedule rates each year, with more future bonuses in future program years.
Despite the release of the MIPS final rule, full details on advanced APMs are still incomplete, our analysis shows. CMS states in the final rule that it expects to release a longer, more detailed list of payment models that will be designated as “advanced” APMs later this year, though time is rapidly running out. The list of ACOs currently recognized as advanced is short, but the agency is required to release its more complete list before Jan. 1, 2017 so that practices could consider whether they would be eligible for APM participation.
— Grant Huang, CPC, CPMA (firstname.lastname@example.org). The author is Director of Content at DoctorsManagement.