CMS Proposes Rule Streamlining Quality-Based Payment Programs.

Date posted: June 2, 2016

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule implementing provisions of the Medicare Access and CHIP Reauthorization Act of 2015.  The proposed rule streamlines several Medicare payment programs into a single framework, known as the Quality Payment Program.  The new program simplifies the approach Medicare uses to pay clinicians for the quality and value of care they provide.  The Quality Payment Program consists of two tracks: (1) the Merit-Based Incentive Payment System (MIPS); and (2) the Advanced Alternative Payment Models (APMs).  Clinicians may switch between the MIPS and APMs depending on which option best fits their clinical needs.

Key provisions of the MIPS include:

  • MIPS will measure overall care delivery and pay providers based on their score in four specified performance categories, including: (1) cost; (2) quality; (3) clinical practice improvement activities; and (4) advancing care information.
  • When submitting information for scoring, clinicians may select the measures and activities most meaningful to their own practice.
  • MIPS will include positive, negative, and neutral adjustments to Medicare Part B payments depending on the variation in scores.
  • Clinicians may use third parties, including registries, health information technology developers, and survey vendors to submit data for performance categories.

Further, key highlights of the APMs include:

  • All clinicians will report through MIPS in the first year to determine whether they meet the requirements for the Advanced APM option;
  • APMs will allow clinicians to accept greater financial risk and earn increased rewards for providing coordinated, high-quality, and efficient care;
  • Clinicians participating in APMs are exempt from MIPS reporting requirements and may qualify for incentive payments; and
  • CMS will annually update the list of payment models qualifying as APMs and will periodically modify models to allow them to qualify as APMs.

CMS will accept public comment on the proposed rule until June 27, 2016.

The proposed rule is available at:

Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under The Physician Fee Schedule, and Criteria for Physician-Focused Payment Models; Proposed Rule, 81 Fed. Reg. 28161, 28161-28586 (May 9, 2016).

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