Based on thousands of comments made on the Quality Payment Program proposed rule, the Centers for Medicare and Medicaid Services (CMS) has laid out a plan to ease participation as eligible clinicians familiarize themselves with the program. CMS has finalized that 2017, the first year of the program, will be a transition year for the Merit-Based Incentive Payment System (MIPS). The first performance year still begins on January 1, 2017, with performance impacting 2019 Medicare Part B payments. However, the changes reduce the length of the performance period required for full MIPS participation in 2017 and provide paths for clinicians to more easily avoid negative payment adjustments.
In 2017, MIPS eligible clinicians will only need to report on a minimum of one continuous 90-day period for the majority of the submission mechanisms.
Furthermore, eligible clinicians have a number of participation options which make it easier to avoid a negative payment adjustment in 2017, while still offering opportunities to earn incentives for full participation.
|Participation Option||Payment Adjustment Impact|
|(1) Full MIPS Participation. Report all measures required under the MIPS program, in all performance categories that require reporting, for a full 90-day period or, ideally, the full calendar year.||Eligible for maximum positive adjustment. Clinicians who meet these requirements are maximizing their chance to qualify for a positive adjustment. Exceptional performers who achieve a MIPS Composite Performance Score of at least 70 out of 100 will be eligible for an additional positive adjustment from a bonus pool of $500 million.|
|(2) Partial MIPS Participation. Report more than one measure in the Quality category, more than one activity in the Improvement Activities category, or more than one of the required measures in the Advancing Care Information category for at least a full 90-day period.||Avoid a negative payment adjustment and be eligible for a positive payment adjustment. Clinicians who meet these requirements will avoid a negative payment adjustment and potentially earn a positive payment adjustment in 2019.|
|(3) Minimum MIPS Participation. Report one measure in the Quality performance category, report one activity in the Improvement Activities performance category, or report the required measures in the Advancing Care Information performance category.||Avoid a negative payment adjustment only. Clinicians who meet these requirements will meet the 2017 MIPS performance threshold (3 points) and avoid a negative 4% payment adjustment in 2019. With this level of participation, there will be no opportunity to earn additional incentive payments.|
|(4) Participate in an Advanced APM. Participate in an Advanced APM in 2017 and meet the minimum Qualifying Participant payment or patient requirements.||Potentially earn the Advanced APM positive payment incentive. MIPS eligible clinicians participating in one or more Advanced APMs who receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM(s) will qualify for a 5% bonus incentive payment in 2019.|
Medicare providers who are eligible for the MIPS payment adjustment who do not meet Advanced APM requirements and choose to not report even one measure or activity under the MIPS program will receive the full negative 4% payment adjustment in 2019.
If 2017 is a transition year, what should we expect in 2018? CMS has already announced the following increased requirements for the 2018 performance period under MIPS:
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