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: 

1. The targeted effective date is 1/1/2017.
2. Eligible providers who report using claims-based reporting will have an increased threshold from 50% to 80%. 
3. Eligible providers who report using a registry will have an increased threshold from 50% to 90%. 
4. Most Medicare-enrolled providers will be considered eligible for MIPS.
5. The one exception to a provider being eligible is to have fewer than 100 Medicare patients and bill less than $10,000 in 2017.
6. 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”).
7. Providers’ performance can result in either an incentive payment or a penalty, either of which could range from 4% to 9% per year.
8. 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. 
    
9. 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.