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MIPS: Seven Key Elements from the 2017 Proposed Rule

The long awaited 2017 proposed rule is here with new information about the future of PQRS and the transition to MIPS, or the Merit-Based Incentive Payment System.

Our team has been pouring over the 900+ page document. There is a lot to cover, but let’s begin with new information about MIPS. Here are the key elements you need to know about:

  1. PQRS, Value-Based Modifier, Quality Tiering and Meaningful Use are being combined into a single program with four performance categories and is called the Merit-Based Incentive Payment System (MIPS).
  2. The four performance categories will look much like their earlier counterparts except for the addition of the performance category Clinical Practice Improvement Activities (CPIA).
  3. Who is eligible: For the first two years, the definition of a MIPS “eligible clinician” (EC) includes physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. At this time, MIPS does not apply to PTs, OTs, LCSWs, and others not listed above.
  4. The program will award a series of points in each performance category and the ECs will receive a payment adjustment (incentive or penalty) based on the total number of points they accumulate with a threshold number of points to avoid a penalty.
  5. What was called “Meaningful Use” or “EHR Incentive Program” is now called “Advancing Care Information.” It removes the requirement for reporting Clinical Quality Measures and allows for a more flexible approach to the measures reported on.
  6. The Quality performance category reporting requirements are proposed to be far more rigorous. Instead of reporting on 50% of eligible Medicare patients, it is proposed to require reporting on 90% of ALL eligible patients, for ALL payers. In most other ways, the proposed rules for this category look much like PQRS, with a few differences on the types of measures that must be reported. And, #7 could be a major difference:
  7. There is a striking absence of information about Measure Groups in the proposed rule. It is not clear if Measure Groups will be included in the list of available measures for 2017. You might want to review our post “Why you should comment on the 2107 Proposed Rule” if you think the loss of Measure Groups will affect you.

Follow our blog and look for webinars with more information about the transition MIPS and the other components of the MACRA Quality Payment Program.

Have questions? Please comment below or contact us.

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