For years, we’ve heard that the Merit-based Incentive Payment System (MIPS) will provide a noticeable incentive for participants in this Medicare FFS program. And for years, there have been reasons why that has not occurred. First, CMS wanted to ‘start slow’ with the MIPS program in 2017 and 2018, so the caps on penalties and incentives were small. Then the potential penalties and incentives were raised, but the threshold for qualifying for an incentive remained low. This, coupled with the program’s budget neutrality meant there was not much revenue to distribute to high performers. Then COVID-19 negated much of the program for the last two years. So here we are, in year five, and we see that the program, for the first time, will have a significant downside and upside potential.
Starting in January, 920 primary care practices will embark on the one of the newest payment models from the Centers for Medicare & Medicaid Services (CMS) via the Primary Care First (PCF) Program. The main criteria for participation in the program are:
- 70% or more of the practice’s collective billing must be for primary care services.
- Use of a 2015 Certified Electronic Health Record Technology (CEHRT) by the practice.
- At least 125 services provided for attributed Medicare beneficiaries.
Also, for the first year of the program, there is a limited geographical area for participation.