On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released its final rule outlining the new payment system for Medicare clinicians, implementing the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) payment provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), collectively called the Quality Payment Program (QPP).
MACRA repeals the Medicare Sustainable Growth Rate methodology for updates to the Physician Fee Schedule and replaces it with the QPP. The ruling covers such issues as data reporting, new practice models, evolving clinical standards, and physician evaluations. According to the U.S. Department of Health & Human Services, the new payment system creates two pathways for clinicians:
- The first provides an opportunity to be paid more for better care and for investments that support patients, while reducing existing requirements. It also provides a more flexible performance period during the first year to allow physicians extra time to prepare.
- The second allows physicians to participate in organizations, such as accountable care organizations. When better health results and reduced costs are demonstrated, physicians receive a portion of the organization’s savings.
Key provisions of the final rule include:
- Clinicians are able to report as individuals or at the group level; that same identifier should be used for all four performance categories (quality, cost, clinical practice improvement activities, and advancing care information).
- The number of measures physicians will report is reduced from nine to six.
- The reporting threshold was finalized at 50 percent for claims, clinical registry, electronic health records (EHR), and qualified clinical data registry mechanisms for the 2017 transition year, with graduation implementation of the higher thresholds in 2018 and beyond.
- The benchmark for resource use assessment is set on the measurement year as opposed to the prior year’s benchmark, and will include episode measures.
- The definition of Clinical Practice Improvement Activities is broader and more flexible. It includes any activity that a MIPS-eligible clinician, organization, or other stakeholder identifies as improving clinical practice or care delivery, and that the Secretary determines is likely to result in improved outcomes when effectively executed.
- CMS has moved away from the “all-or-nothing” measurement standard used in the current Meaningful Use program to one that awards partial credit for certain components of EHR use and reduces the total number of required measures from eleven in the proposed rule to five in the final rule.
CMS will accept public comments on the final rule until December 19, 2016.
Sources: U.S. Department of Health & Human Services press release, October 14, 2016; American Society of Hematology press release, October 14, 2016.