MIPS Mastery is a seven-part series on optimizing performance under the Merit-Based Incentive Payment System, originally produced by PYA.
First, the Good News:
2016 will be the last year physicians must report scores on specified performance measures to the Centers for Medicare & Medicaid Services (CMS) to avoid up to a 9% reduction in Medicare Physician Fee Schedule (MPFS) payments under the Physician Quality Reporting System (PQRS), the Value-Based Modifier (VM) Program, and the Meaningful Use (MU) Program.
Next, the Not-So-Good News:
Today’s reporting requirements may prove to be “easy” compared to what’s ahead. A physician’s 2017 scores on performance measures in four weighted categories – quality, resource use, advancing care information, and clinical practice improvement activities – will dictate that physician’s 2019 composite performance score (CPS) under the new Medicare Incentive Payment System, or MIPS. The CPS, expressed as a number from 1 to 100, will be used by CMS to determine the physician’s 2019 MPFS payment rate. CMS also will report the physician’s CPS publicly on the Physician Compare website.
How Did We Get Here?
Back on April 16, 2015, the President signed into law the Medicare Access and CHIP Reauthorization Act. MACRA repealed the much-despised sustainable growth rate (SGR) formula for determining MPFS payments. In its place, Congress directed CMS to implement MIPS, a new physician payment system that incentivizes quality and efficiency rather than merely rewarding volume. A year later, on May 9, 2016, CMS published its much anticipated 426-page MIPS Proposed Rule. According to the agency, it has striven to “propose a program that is meaningful, understandable, and flexible with a critical focus on transparency, effective communication with stakeholders, and operational feasibility.” The underlying MIPS concept is relatively straightforward: a physician whose CPS is above the national performance threshold established by CMS will receive an upward adjustment to his or her MPFS payments (up to 4% in 2019, increasing to 9% by 2023), while a physician whose CPS is below that threshold will be subject to a corresponding downward adjustment. CMS’ proposed processes for identifying specific performance measures, compiling data and calculating each physician’s CPS, establishing performance thresholds, and making payment adjustments, however, are anything but straightforward. The first step on the road to MIPS Mastery™ is gaining a working knowledge of those processes. From that point, you can begin making strategic decisions to maximize your CPS. By making the right choices and following through on those decisions, you can improve reimbursement and enhance your reputation among providers, payers, and patients. The following highlights key provisions of the proposed rule. CMS will publish the MIPS final rule this fall, just in time for the beginning of the first performance period January 1, 2017.