Final Rule on the Medicare Quality Payment Program

On Friday, October 14, CMS released its highly-anticipated Final Rule on the Medicare Quality Payment Program, otherwise known as MACRA.  Here are the key headlines for UR members:

1. You will have to report MIPS, but you are unlikely to see a payment adjustment for reporting year 2017.  

CMS is establishing calendar year 2017 (corresponding with payment year 2019) as a “transitional” year for the Merit-Based Incentive Program (MIPS), meaning the bar for avoiding a negative payment adjustment under MIPS will be considerably lower than set out in April’s proposals. You will be able to report 90 days of data rather than a full year of data.  To avoid a negative payment adjustment, all you will need to do is report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information (ACI) performance category. However, it is very important that you meet at least these minimum reporting requirements, because those that fail to do so will incur a -4% payment adjustment. As long as you meet the minimum reporting requirements, you will not incur a downward payment adjustment. However, you are unlikely to incur an upward payment adjustment in the first year either, since the program is budget neutral (meaning that the relatively small number of providers that will have downward adjustments effectively fund the upward adjustments).

2. In the first year of MIPS, you will not be assessed on cost.  

The cost component of MIPS will also now have a zero weight for this first transition year, which means that the cost of care will only begin to affect MIPS payment adjustments in 2018 (payment year 2020).

3. Participants in Advanced Alternative Payment Models will begin to receive bonuses in 2017, but currently, these do not apply to most UR members.  

The Final Rule finalizes most of April’s proposals in relation to the “Advanced Alternative Payment Models” under which participants are MIPS exempt and can receive a 5% bonus. “Advanced APMs” for 2017 will include Comprehensive ESRD Model (non-LDO two-sidedisk arrangement); Comprehensive ESRD Care Model (LDO arrangement); Comprehensive Primary Care Plus (CPC+) model; Medicare Shared Savings Program (Track 2 or 3);  Next Generation ACO Model; and Oncology Care Model (two-sided risk arrangement).  The Advanced APM category will evolve over time.

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