CMS released the eagerly-awaited Final Rule implementing the new Medicare physician Quality Payment Program (QPP) as authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The QPP incentivizes quality physician services through the Merit-based Incentive Payment System (MIPS) which adjusts Medicare reimbursement beginning in 2019 based on physician performance measured in 2017 and beyond. Physicians may be exempted from MIPS adjustments and may receive a bonus payment for participating in CMS-approved Advanced Alternative Payment Models (Advanced APMs). CMS made significant changes from the Proposed Rule:
- Creation of a MIPS transition year and iterative learning and development period in 2017;
- Adjustment of the low-volume threshold so that MIPS is not required for physicians with less than $30,000 Medicare Part B allowed charges per year or less than 100 Medicare patients
- Expansion of the list of Advanced APMs, participation in which allows for receipt of a 5 percent bonus and exclusion from MIPS. The list consists Comprehensive ESRD Care Model, Comprehensive Primary Care Plus Model, Medicare Shared Savings Program Tracks 2 and 3, and the Next Generation ACO Model. (CJR is on track to be added to this list for 2017 under a separate process); and
- Simplification of prior “all-or-nothing” requirements in the use of certified EHR technology
