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Medicare Payment Reform: The Merit-Based Incentive Payment System (MIPS) & Alternative Payment Models (APMs)

Medicare Payment Reform: The Merit-Based Incentive Payment System (MIPS) & Alternative Payment Models (APMs)

In late April 2016, the Centers for Medicare and Medicaid Services (CMS) released a notice of proposed rulemaking to implement key provisions of the Medicare Access and CHIP Authorization Act of 2015 (MACRA). This legislation, passed in April 2015, was designed to eliminate the flawed sustainable growth rate (SGR) formula for adjusting Medicare payments to providers, and to establish a new payment system focused on high quality, low cost, patient-centered care.  The proposed rule would implement the changes outlined in MACRA through a unified framework called the “Quality Payment Program.” There are two paths to participation under this program. The first is through the Merit-based Incentive Payment System (MIPS) and the second is through Advanced Alternative Payment Models (APMs). 

CMS currently has a number of programs in place designed to measure the quality and cost of health care services provided under the Medicare program. These programs include the Physician Quality Reporting System (PQRS), Value Modifier Program (VM) and the Medicare Electronic Health Record (EHR) Incentive Program. At this time, audiologists are excluded from both the VM and Meaningful Use of EHR programs. Under MIPS, payment adjustments will now be calculated across four categories: quality, resource use, clinical practice improvement activities, and advancing care information. To make the transition to quality reporting under MIPS, PQRS will sunset in the performance year of 2017. This means that 2016 is the final year in which providers will be required to participate in the PQRS program. The year 2017 marks the first performance year for MIPS, with payment adjustments being distributed in 2019. It is important to note that audiologists are not eligible for participation in MIPS in the first two years (2017, 2018). The Secretary of the US Department of Health and Human Services (HHS) has the authority to include other professionals, including audiologists, beginning in 2019. This means that audiologists will not be required to report on anything in 2017, but will have the option to “practice” reporting on measures through MIPS. The Academy has developed a fact sheet to assist audiologists with voluntary reporting under MIPS

The Academy has been actively following the evolution of these programs since the passage of this MACRA legislation and has offered comments on various aspects of these programs.  Those comments are below.  The Academy will continue to update its members as we conduct further analysis of these programs and develop additional resources.

Academy Comments on MIPS/APMS

December 2016: Final Rule Addressing Implementation of MIPS and APM Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models

 June 2016: Notice of Proposed Rulemaking on MIPS and APM Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models

 March 2016: Draft CMS Measure Development Plan

 November 2015: Request for Information Regarding Implementation of the MIPS, Promotion of APMs, and Incentive Payments for Participation in Eligible APMS

 August 2015: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016 (MPFS Proposed Payment Rule)

Resources and Information Addressing MIPS/APMS

CMS Proposes Quality Payment Program Updates

CMS’ New Quality Payment Program Web site

US Department of Health &Human Services Press Release on MACRA Implementation and CMS Rulemaking

Also of Interest