2016 MU participation is crucial to avoid a 2018 payment adjustment
We have just passed the July 1st application deadline for hardship for the 2015 Meaningful Use program, and it's ironic that we are already analyzing the MU replacement program. Many physicians stopped participating in Meaningful Use prior to 2015 due to the administrative burdens, time constraints and the complexity of the program.
Many managers who have listened to a CMS National Call or viewed a webinar related to the Merit-Based Incentive Payment System are already concerned with the transition. It is important for providers and managers to understand that 2016 Meaningful Use participation is crucial to avoid a 2018 adjustment to Medicare payments since the Merit-Based Incentive Payment System will not be implemented until January of 2017.
The April 27, 2016 proposed rule issued by the Centers for Medicare and Medicaid Services implements key provisions to replace the Sustainable Growth Rate Formula. The new approach to paying clinicians for value and quality includes two paths: The Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Model (APM). Small practices will be allowed flexibility in the MIPS program if the size of the group consists of 15 or fewer clinicians or if the practice is located in a rural area or is located in a health professional shortage area.
The Advancing Care Information portion of MIPS replaces Meaningful Use beginning January of 2017. The proposed rules will not impact EPs in Medicaid program or hospitals. The proposed program will:
- Allow physician flexibility in choosing measures that reflect how EPs use EHR technology
- No longer require an all or nothing measurement for quality by CMS
- Reduce measures from 18 to 11
- No longer require reporting of clinical decision support and Computer Order Entry
- Only require EPs to report to a single public registry
- Exempt some physicians when EHR technology is less applicable.
The new MIPS program replaces the single track programs known as Meaningful Use, PQRS and the quality and cost components of the Value Based Modifier. MIPS further transitions the payment system from fee for service to quality and value in four categories:
- Cost 10 % Based on Medicare claims, no reporting (formerly VBM)
- Quality 50% Six measures vs nine (formerly PQRS and VBM)
- Clinical Practice Improvement 15% Focus on care coordination- 90 options
- Advancing Care Information 25% Use of EHR technology (formerly MU)
Many practice leaders have stated that their lack of participation in previous programs were due to low Medicare or Medicaid patient volume. However, we have seen most commercial carriers adopt the same initiatives on cost, quality and care coordination. As a healthcare consultant I am concerned for those practices that are continuing to practice using paper charts and outdated practice management systems that limit patient focus. Payment adjustments for lack of participation and positive adjustments for successful performance will be awarded based on the table below:
2019 2020 2021 2022 and after
4% 5% 7% 9%
According to the law, during the first five payment years of the program, $500 million is provided for an additional performance bonus that is exempt from budget neutrality for exceptional performance. The gradual increase for exceptional performance would not be higher than an additional 10% based on the MIPS score.
Incentive payments can also be earned through participation in Advanced Alternative Payment Models known as:
- Comprehensive End Stage Renal Disease Care Model
- Comprehensive Primary Care Plus
- Medicare Shared Savings- Track 2
- Medicare Shared Savings- Track 3
- Next Generation ACO Model
- Oncology Care Model Two-Sided Risk Arrangement (2018)
Incentive payments for significant participation in Advanced Alternative Payment Models begin in 2019 for practices that earn 25% of their payments through Advanced APM or 20% of their patient base is through an Advanced APM. These parameters increase to 50% and 35% in 2021 and to 75% and 50% in 2024 respectively.
Starting in performance year 2019, a clinician could qualify for incentive payments for participation in Advanced APMs developed by non-Medicare payers such as private insurers or state Medicaid programs. It is important for practice leaders to stay informed as the proposed programs are implemented. We are quickly approaching the MIPS implementation date and this valuable time should be utilized to assess your practice management systems, electronic health record systems and interfaced products available to you. It is important to meet with your vendors to assure you have the correct resources to align your practice for participation in upcoming programs and incentives.
Tammie Lunceford is a healthcare consultant with Warren Averett.
