The Medicare Access and CHIP Reauthorization Act (MACRA), passed by Congress in 2015, repealed the Medicare sustainable growth rate physician payment formula and replaced it with a new payment system that represents a framework for rewarding providers for giving better care rather than more care. On Oct. 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released the much-anticipated final rule implementing MACRA.
Under the new Quality Payment Program (QPP), physicians and other providers paid under the physician fee schedule can choose one of two paths to payment: the Merit-Based Incentive Payment System (MIPS) or participation in an alternative payment model (APM). Fee schedule payments will be tied to this new system beginning in 2019, although the performance period start on Jan. 1, 2017.
To encourage participation in the new payment program, CMS is permitting clinicians to “pick their pace” for the 2017 performance period. Clinicians will be exempt from payment penalty in 2019 if they choose any one of the following options:
1) Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment.
2) Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.
3) Clinicians can report any information to avoid a negative adjustment. This could include one measure in the quality performance category; one activity in the improvement activities performance category; or all the required measures of the advancing care information performance category. If MIPS eligible clinicians do not report even one measure or activity, they will receive the full negative 4 percent adjustment.
4) MIPS eligible clinicians can participate in Advanced APMs.
The 90-day reporting period can occur anytime between January 1 and October 2, 2017.
Medicare-enrolled clinicians who will be excluded from MIPS, include newly Medicare-enrolled MIPS eligible clinicians, Advanced APM Qualified Participants (QPs), certain partial QPs, and clinicians that fall under the low-volume threshold, which has been finalized as clinicians who have less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients. MACRA does not affect facility payments.