April was a busy month for CMS. Following a month of announcements regarding all areas of care, the agency announced details for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which replaces the sustainable growth rate (SGR) physician fee schedule with a new Merit-based Incentive Payment System (MIPS) for eligible clinicians or groups under the Physician Fee Schedule.
Under the ambitious proposed rule, MIPS would consolidate components of the Physician Quality Reporting System, the Physician Value-based Payment Modifier, and the Medicare Electronic Health Record Incentive Program for Eligible Professionals. The MIPS program “would continue the focus on quality, resource use, and use of certified EHR technology (CEHRT) in a cohesive program that avoids redundancies,” the HHS stated April 27.
MIPS authorizes CMS to pay Medicare Part B providers for delivering high-value care in four performance categories, based on a score of 0 to 100 points. The categories are:

  • Quality (50% of total score in year 1): Clinicians would report on six measures from among a range of options that accommodate differences among specialties and practices.
  • Advancing Care Information (25% of total score in year 1): Clinicians would choose to report customizable measures that reflect how they use technology in their day-to-day practice, with a particular emphasis on interoperability and information exchange. Unlike the existing reporting program, this category would not require all-or-nothing EHR measurement or redundant quality reporting.
  • Clinical Practice Improvement Activities (15% of total score in year 1): This category would reward clinical practice improvements, such as activities focused on care coordination, beneficiary engagement, and patient safety. Clinicians may select activities that match their practices’ goals from a list of more than 90 options.
  • Cost (10% of total score in year 1): For this category, the score would be based on Medicare claims, meaning no reporting requirements for clinicians. This category would use 40 episode-specific measures to account for differences among specialties.

The proposed rule seeks to streamline and reduce the reporting burden, while adding flexibility for physician practices, according to HHS. However, practices must pay attention to their scores because a negative score could impact Medicare reimbursement, and the scores will be available on the Physician Compare website.
CMS would begin measuring performance for doctors and other clinicians through MIPS in 2017, with payments based on those measures beginning in 2019.
Will it work? Physician organizations aren’t sure. The success of CMS’s move to pay physicians based on the quality of the care they provide, rather than the quantity they deliver, will depend on how CMS goes about measuring quality and whether those measurements generate additional administrative burdensfor practices.  According to a recent HealthAffairs study, physician practices already spend more than $15.4 billion per year to report quality measures.
The American Medical Association lauded the proposal for revamping the Meaningful Use program, but the American Hospital Association panned the narrow range of programs in the Advanced Alternative Payment Models. Nothing is set in stone yet, as AMA noted. The proposed rules are the first step in the process, and CMS is taking comments from now through June 27 at 5 p.m.
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Last Updated on April 18, 2016