July 21, 2017

Proposed MPFS Rule Eases Transition to MIPS

The Medicare Access and CHIP Reauthorization Act (MACRA) was intended, in part, to streamline and simplify legacy quality measurement programs. These would include the Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM) and the Electronic Health Record (EHR) Incentive Program.

Calendar Year (CY) 2016 was the last reporting period for PQRS. Clinicians had from January to March 2017 to submit their 2016 PQRS quality data to avoid a downward payment adjustment in 2018.

With the new Merit-based Incentive Payment System (MIPS) under MACRA, the Centers for Medicare & Medicaid Services (CMS) made several positive changes that do not affect payments until 2019. MIPS is replacing PQRS under Medicare’s Quality Payment Program (QPP). The first MIPS performance period is January through December 2017.

In the proposed CY 2018 Medicare Physician Fee Schedule (MPFS) rule, CMS acknowledged the influence of stakeholder feedback. CMS also cited a need for a better alignment with the MIPS data submission requirement for the quality performance category. Thus, CMS is proposing retroactive changes to the 2016 PQRS, VM and the Meaningful Use program. These would ease requirements and reduce penalties that would affect clinicians in 2018.

Individual eligible professionals and group practices that did not satisfactorily report data on quality measures in 2016 for PQRS are subject to a downward payment adjustment of 2.0 percent in 2018 for their MPFS services.

CMS is proposing to reduce PQRS reporting requirements from nine to six measures. This is required in the MIPS quality category. The agency proposes similar changes to the clinical reporting requirements under the EHR Incentive Program for eligible professionals.

CMS also proposed the following changes to previously finalized policies for the 2018 Value Modifier.

They say these changes would improve incentive alignment and provide a smoother transition to MIPS:

  1. Reducing the automatic downward payment adjustment for not meeting minimum quality reporting requirements: from negative 4 percent to negative 2 percent for groups of 10 or more clinicians and from negative 2 percent to negative 1 percent for physician and non-physician solo practitioners and groups of two to nine clinicians
  2. Holding harmless all physician groups and solo practitioners who met minimum quality reporting requirements from downward payment adjustments for performance under quality-tiering for the last year of the program
  3. Aligning the maximum upward adjustment amount to two times the adjustment factor for all physician groups and solo practitioners

Revisions are described in this CMS fact sheet.