The proposed rule for MACRA and the Merit-based Incentive Payment System (MIPS) program was released June 21, 2017. As expected, the program requiring the implementation of the new MIPS scoring system and incentives to move to alternative payment models (APMs) will continue.
This proposed rule represents a modification of the 2018 requirements as the program is phased in over a period of 4 years. The Department of Health and Human Services has limited ability to change the requirements of the program. The modifications in the proposed rule for 2018 are felt to fit within the framework of the legislation. Penalties and bonuses in the program were set by the MACRA legislation that fixed the sustainable growth rate and required the implementation of the MIPS program for traditional Medicare while providing additional money for growth of APMs. In this article, we will focus on the proposed rule’s effect on MIPS.
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Recall that the MIPS program introduced last year included four categories, each of which made up a percentage of the final score for the program. The four categories that make up the MIPS score include Quality (formerly the Physician Quality Reimbursement System), Improvement Activities, Advancing Care Information (formerly Meaningful Use), and Cost (formerly the value-based modifier).
The data for each of the MIPS year are collected 2 years prior to the implementation of the bonus or penalty. For example, data submitted for 2017 will impact payments for the 2019 payment year.