Today, the Department of Health and Human Services (HHS) released the final rule with comment period for the Quality Payment Program under MACRA. Consistent with what was discussed in the proposed rule, the MACRA Quality Payment Program will have two tracks: (1) Advanced Alternative Payment Models (APMs) and the Merit-Based Incentive Payment System (MIPS). This is part two of our summary of the final rule, and will cover the pacing options available under MIPS. To read more about MIPS Eligibility and the MIPS performance categories, please check out Part 1!
Recently, we discussed how otherwise eligible clinicians could be exempted from the entire MIPS program. However, under the individual performance categories for MIPS (Quality, Advancing Care Information, Resource Use, and Clinical Practice Improvement Activities), there are some special circumstances that will allow for a partial exemption.
After hosting our first ever MIPS webinar, we found that the majority of the questions being asked surrounded MIPS eligibility. In particular, the low-volume threshold was of interest. Since this is a topic we have yet to fully delve into, we decided that we should do so now!
Compared to the current CMS quality initiatives, the pool of eligible clinicians (formerly called eligible providers) will be shrinking significantly for the 2017 performance year. However, any clinician that bills Medicare Part B can practice reporting for MIPS in 2017. Considering that by 2019, when the pool of eligible clinicians will expand, the MIPS payment adjustment will be up to 9%, it is likely wise to report even if you are not an eligible clinician in 2017.
When I was in college, MIPS used to stand for “millions of instructions per second,” a measurement of how fast your computer performs. With MACRA on the horizon, MIPS now stands for "Merit-Based Incentive Payment System." While its aim is to measure value of care, MIPS is now a measurement of how fast your practice can accommodate pay-for-performance reimbursements. With MIPS fast approaching, preparing for the upcoming changes is critical.