MIPS: How you will be measured going forward
‘Composite score’ incorporates quality performance, cost, EHR use, clinical practice improvement
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) establishes the Merit-Based Incentive Payment System (MIPS) to measure quality and resource use and adjust payments to providers based on performance in these and other categories. On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) released its proposed rule for implementing MACRA, and while the details are not final, they give a clear indication that most urologists will be subject to MIPS payment adjustments (see “MACRA pay models: What you can expect") and will need to understand the basics of the incentive program in order to thrive.
In this second installment in a series, I will address who is covered by MIPS, how and when you will be measured, and how and when you will receive your payment adjustment.
Who is covered by MIPS?
MIPS is the default incentive program, and everyone is in MIPS unless they meet one of three exceptions: first year of participation in Medicare, do not exceed a low volume threshold of Medicare payments or patients, or qualifying participation in an advanced alternative payment model (as defined by CMS). CMS estimates that over 85% of urologists in the Medicare Part B program will be in MIPS.
The proposed rule further clarifies that physicians, physician assistants, nurse practitioners, and clinical nurse specialists will be subject to MIPS at the outset, and in subsequent years physical therapists and almost every other type of health care professional who bills Medicare will be measured and paid under MIPS. Finally, the proposed implementation will allow clinicians in groups to participate in MIPS as individuals or as a group.
How and when will you be measured under MIPS? MACRA stipulates that the first payment adjustments will occur as positive or negative fee schedule adjustments in 2019 (payment year). The proposed rule clarifies that, as with all previous payment adjustment programs under CMS, the performance period will begin 2 years earlier and be an entire year (with a few exceptions).
CMS expects to have issued a final rule by fall 2016 and has clearly signaled an intention to implement MIPS performance measurement in January 2017. For example, the proposed rule outlines alternative paths forward through the first 2 years of MIPS measurement (2017 and 2018) that roughly map to the existing meaningful use stages—which MIPS would replace.