The Centers for Medicare and Medicaid Services (CMS) received nearly 4,000 comment letters after issuing the draft rule in April on implementing the Medicare Quality Program, which includes both Merit Based Incentive Payment System (MIPS) and Alert native Payment Methods (APMS). Many comments urged a delay in MIPS implementation and more flexibility.
After talking to thousands of physicians and other clinicians across the country, Andy Slavitt, acting administrator of CMS, responded in a CMS blog, with several options for physicians.
First Option: Test the Quality Payment Program. This option would allow physicians to submit some data to the program to avoid a negative payment adjustment. It’s designed to let physicians test to see that their system is working so they learn more and be prepared for broader participation in 2018 and 2019.
Second Option: Participate for part of the calendar year. Physicians could choose to submit Quality Payment Program information for a reduced number of days, with the first performance period beginning later than Jan. 1, 2017. Those practices could still qualify for a small positive payment adjustment.
Third Option: Participate for the full calendar year. Practices that are ready to start Jan. 1, 2017, could submit Quality Payment Program information for a full calendar year. Practices that submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking could qualify for a modest positive payment adjustment.
Fourth Option: Participate in an Advanced Alternative Payment Model in 2017. Instead of reporting quality data and other information, physicians can participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. Physicians who receive enough Medicare payments or see enough Medicare patients through the Advanced Alternative Payment Model in 2017 would qualify for a 5 percent incentive payment in 2019.
Implementing Medicare’s new payment program remains a tough road for some practices, especially ones that don’t have Electronic Health Records systems or have never reported performance data.
These changes may not be the last – stay tuned. Contact KMA at firstname.lastname@example.org with questions about the New Medicare Quality Payment System