Merit-Based Incentive Payment System
The Centers for Medicare and Medicaid (“CMS”) issued a proposed rule featuring information related to the Merit-Based Incentive Payment System (“MIPS").
The following is an overview of some key areas:
- The targeted effective date is 1/1/2017.
- Eligible providers who report using claims-based reporting will have an increased threshold from 50% to 80%.
- Eligible providers who report using a registry will have an increased threshold from 50% to 90%.
- Most Medicare-enrolled providers will be considered eligible for MIPS.
- The one exception to a provider being eligible is to have fewer than 100 Medicare patients and bill less than $10,000 in 2017.
- One scorecard will replace the current 3 quality-reporting programs of (1) meaningful use, (2) physician quality reporting system (“PQRS”) and (3) the value-based modifier (“VBM”).
- Providers’ performance can result in either an incentive payment or a penalty, either of which could range from 4% to 9% per year.
- There are 4 new reporting categories:
- Quality – replaces PQRS – 50% of total performance score.
- Advancing clinical information – 25% of total performance score.
- Value-based modifier – 10% of total performance score.
- Clinical practice improvement activities – 15% of total performance score.
- The new clinical practice improvement activity category relates to practice improvement activities (e.g., expanded practice access, population management, care coordination, etc.).
The MIPS program will have a significant and enduring impact on how health care is delivered in our society. We will continue to update you on any changes to this important proposal.