Dear Friends:
The Medicare Access and CHIP Reauthorization Act (MACRA)
/Merit-based Incentive Payment System (MIPS) final rule has been released unexpectedly this morning.
Now we can call it meaningful changes instead of meaningless use.
The Centers for Medicare and Medicaid Services (CMS) has made substantial changes. We are extremely pleased that they have accepted at least part of our recommendation in reference to a 90-day period reporting rather than full year.
However, the 90-day period was ASIPP's idea. It really helped us to go to Washington and advocate for our positions.
Here is the summary of MIPS as we read it. We are very optimistic, but again, we are cautiously optimistic.
More good news is in the works for interventional pain physicians on MIPS registries, etc. We will keep you posted.
CMS will create a 90-day reporting period for clinicians reporting in MIPS, the final rule states. The agency is reducing the number of measures to be reported from 11 to five. Providers will have the option of reporting all the dropped measures.
Reporting to public health or clinical data registries will result in a bonus. CMS is also exploring whether to count managing referrals and consults as part of the MIPS reporting.
The final rule also outlines CMS's "pick-your-pace" route to MIPS reporting. Given the wide diversity of clinical practices, the initial development period of the Quality Payment Program implementation would allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017.
(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. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
(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 choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment. Alternatively, if MIPS eligible clinicians choose to not report even one measure or activity, they will receive the full negative 4 percent adjustment.
(4) MIPS eligible clinicians can participate in Advanced Alternative Payment Models (
APMs), and if they receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM, they will qualify for a 5 percent bonus incentive payment in 2019.
(5) Other provisions:
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Financial and technical assistance (100 million) to small and rural practices
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Teases that more advanced APMs will be available by January 2017
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Finalizes most of the APM portions of the proposed rule
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New estimate is 200 million distributed under MIPS, down from 833 million
Laxmaiah Manchikanti
, MD
Chairman of the Board and Chief Executive Officer, ASIPP and SIPMS
Medical Director, Pain Management Center of Paducah
Clinical Professor, Anesthesiology and Perioperative Medicine
University of Louisville
, Kentucky
2831 Lone Oak Road
Paducah
, KY 42003
270-554-8373 ext. 101
Aaron K. Calodney, MD
President, ASIPP
NeuroCareNetwork
PO Box
130459
Tyler
, TX 75713-0459
903-531-2500
