The Center for Medicare and Medicaid Services (CMS) has published a “Request for Information” (RFI) regarding the implementation of the Merit-Based Incentive Payment System (MIPS) and alternative payment models (APMs) under the “Medicare Access and CHIP Reauthorization Act” (MACRA), which was passed back in April to replace the Sustainable Growth Rate (SGR) formula used to calculate Medicare payments to physicians. AANEM will be submitting its comments by the November 17, 2015 deadline, but individuals are also allowed to submit comments.
Specifically, CMS is looking for input regarding what MIPS should look like. As you will recall, MIPS will replace/combine CMS’s three current quality/value programs (Meaningful Use/EHR, Value-Based Modifier and PQRS) into a single payment program effective on January 1, 2019. CMS is also looking for comments on what a qualified APM should look like. As of January 2019, physicians will have the option of participating in MIPS or an APM.
Here is a summary of the RFI from CMS:
Section 101 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repeals the Medicare sustainable growth rate (SGR) methodology for updates to the physician fee schedule (PFS) and replaces it with a new Merit-based Incentive Payment System (MIPS) for MIPS eligible professionals (MIPS EPs) under the PFS. Section 101 of the MACRA sunsets payment adjustments under the current Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VM), and the Electronic Health Records (EHR) Incentive Program. It also consolidates aspects of the PQRS, VM, and EHR Incentive Program into the new MIPS. Additionally, section 101 of the MACRA promotes the development of Alternative Payment Models (APMs) by providing incentive payments for certain eligible professionals (EPs) who participate in APMs, by exempting EPs from MIPS if they participate in APMs, and by encouraging the creation of physician-focused payment models (PFPMs). In this request for information (RFI), we seek public and stakeholder input to inform our implementation of these provisions.
The RFI is long (>20 pages) and complicated but you are not required to comment on every section or even every question in a section. For example, AANEM plans to comment on, among other things, (1) the lack of applicable quality measures for our members and how to deal with that (section II-A-3a.) and (2) technical assistance for small and rural practices, as CMS has provided this for some of its other quality payment programs but, with the way it was set-up in the past, it was only really available to primary care/general practitioners and not specialists (section I-C). So feel to comment on any section you feel will have the greatest impact on your practice.
You can access the full RFI and directions for comment submission here
All comments are due on November 17, 2015 by 5 p.m. EST. CMS has announced that it will release its Proposed Rule on this topic in the early spring, at which time the public will have another opportunity to comment.