Medicare Finalizes New Physician Payment System Rules for MIPS & MACRA
Last week, the Centers for Medicare & Medicaid Services (CMS) released a final rule implementing a new Medicare physician payment system, which replaces the flawed sustainable growth rate formula and marks the most significant change to Medicare physician reimbursement in 20 years. Beginning in 2017, physician practices can choose between two payment tracks – the Merit-Based Incentive Payment System (MIPS) and risk-based alternative payment models (APMs). At the outset, there are relatively few APM opportunities, and CMS estimates that more than 90% of physicians will participate in MIPS, making it the default track.
MIPS increases or decreases physician Medicare reimbursement rates based on performance on measures in four categories: quality, cost, EHR use, and clinical practice improvement activities. Payments in 2019 will be adjusted based on 2017 performance, and the cost category will not be counted in 2017. 2017 will be a transition year and physician practices will have four options for engaging in MIPS:
- Report all required measures for at least 90 consecutive days and be eligible for a bonus payment;
- Report more than one quality measure, more than one improvement activity, and the required EHR measures for at least 90 consecutive days and be eligible for a small bonus payment;
- Report one quality measure, one improvement activity, or the required EHR measures and avoid a penalty; or
- Do nothing and receive a 4% payment penalty in 2019.
Do Not Delay MACRA Implementation
According to Medicare’s 2014 PQRS Experience Report published in April 2016, 45% of healthcare in the United States occurs in practices of 10 or fewer providers. There are 453,000 Providers in 256,000 Practices nationwide that share small practice barriers to delivering data about quality to Medicare. Anything that is disastrous to those practices puts 45% of healthcare access at risk. Compared to their peers in larger practices, these small practices are less likely to have an Electronic Medical Record. If they have an Electronic Medical Record, they are unlikely to have affordable access to electronic reporting. And they are less likely to participate today in Medicare’s Physician Quality Reporting System.
First, there are problems with the MACRA & MIPS proposed rule that are disastrous to small practices. There are problems that will not be fixed with a one, two, or even ten-year delay. And the problems could be fixed with some simple modifications to the proposed rules.
Second, the complex array of programs that MACRA will replace have significant dysfunctions. It will be beneficial to most of us to replace those programs as quickly as possible to alleviate those dysfunctions.
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