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Historic Medicare payment policy changes

May 9, 2016

Historic Medicare payment policy changes

The way you report to get paid by Medicare changes in eight months on January 1, 2017. Up until now we’ve had a framework, now we have the details – 1,000 pages of details.

On April 27, CMS published a Notice of Proposed Rulemaking (NPRM) defining the largest change in Medicare physician payment policy in the last 25 years! The Advocacy Council will be submitting comments to CMS once we’ve had a chance to analyze the full document.

We’ve known that there are two payment paths, the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). What’s new?

  • The requirements for each of the four MIPS categories (Quality, Advancing Care Information (previously known as Meaningful Use), Clinical Practice Improvement Activities and Resource Use) have been defined.
  • The following requirements for APMs have been further refined:
    • Participants bearing a certain amount of financial risk.
    • Payments being tied to reporting of quality measures comparable to those used in the MIPS quality performance category.
    • Participants using certified EHR technology.
  • CMS announced that certain programs will qualify as APMS. These include the Medicare Shared Savings Program (tracks 2 and 3) and the Next Generation ACO.

While we have not completed our analysis of the complete document, we have some initial thoughts on the proposed rule:

  • MIPS reporting requirements appear to provide greater flexibility than the old PQRS, Meaningful Use and Value-Based Modifier programs. The new program is no longer all or nothing; partial credit is available for MIPS components. In particular, the Advancing Care Information program will be easier for providers to meet.
  • CMS has tried to align the standards for MIPS and APMs to make it easy for clinicians to move between the two programs.
  • CMS is encouraging specialties to develop Physician-Focused Payment Models, which may also qualify as APMs. This is good news for allergists, as the Advocacy Council is currently working on your behalf to develop an Asthma APM for our specialty.
  • CMS is giving providers time to adjust to the new program by lessening payment adjustments in the early years. 2019 MIPS adjustments of +/- 4% will be LESS than current the PQRS/MU/VBM program, which in 2018 will range from +/- 7% to +/-9% depending on practice size.

The Advocacy Council of ACAAI will continue to review the proposed rule and provide updates to our members. We are here to guide you through the steps required to participate in the new Quality Payment Program.

If you’d like to learn more, we suggest the following:

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