If you are not already involved in an Advanced Alternative Payment Model, it is not too late to participate in the first year of the Merit-based Incentive Payment System (MIPS). However, you must act within the next few days or risk a reduction of 4% or more in your reimbursement rate.
The transition year of the Merit-based Incentive Payment System (MIPS) has been underway since January 1, 2017 and runs until December 31, 2017. However, data collection must begin no later than October 2, 2017, in order to satisfy the minimum of 90 days of data reporting required for the transition year. If you are planning to submit 90 days of your quality data via your claims, you must begin adding the applicable quality data codes to your claims no later than Monday, October 2nd.
Under the Rule currently in effect, Physicians who charge $30,000 a year or less for Medicare Part B services or see 100 Medicare Part B patients or fewer per year are exempt from participation in MIPS. Additionally, CMS has made it clear that physicians are not required to participate in MIPS in the “transition year” of 2017 (that is, unless you don’t want to experience an automatic 4% reduction in the Medicare reimbursement rates in 2019). Because the downward adjustments will increase each year thereafter, there is little or no advantage for an eligible physician not to participate in 2017, even if they are exempt.
The good news is, you can avoid the 4% downward adjustment by submitting data on one Quality Measure or one Improvement Activity in 2017. If you submit “more than minimal” data on three categories (Quality, Cost, & Improvement Activities), not only can you avoid the negative adjustment, but you may also earn a positive payment adjustment.
According to CMS, the Quality Payment Program signals a shift in reimbursement from the volume of services provided, toward a payment system that rewards clinicians for their overall work in delivering the best care for patients. This clearly indicates CMS’s commitment to fundamental “transformation of payment to clinicians based on value.” All indications are that the positive adjustments will likely increase in succeeding years for those who can show a commitment to quality and value. But, you must act NOW!
Dennis Sadler received a J.D. from the University of Memphis, Cecil C. Humphreys School of Law and an L.L.M. in Health Law, with a Concentration in Compliance, from Loyola University, Chicago School of Law. He is a Member of the law firm of Leitner, Williams, Dooley & Napolitan, where his practice focuses on health law, construction law, and products liability.