CMS Doubles-Down on MIPS; 2019 expected payment reductions in the proposed program changes triple.

CMS’ recently proposed updates to the Quality Payment Program make one thing perfectly clear: CMS is doubling down on value-based care. Despite some vocal resistance, both the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs) are here to stay. In fact, CMS has expanded the Quality Payment Program for 2019, increasing both the number of eligible clinicians and the amount of Medicare Part B reimbursement at risk. In the proposed rule key updates to the Program include:

  • Expansion of the definition of eligible clinicians to include 650,000 clinicians, up from 604,000. New eligible clinician types include physical therapists, occupational therapists, and clinical social workers;
  • More than triples the expected negative adjustments from $118 million to $372 million;
  • Doubles the performance score required by providers to avoid negative payment adjustments;
  • Increases the importance of cost of care in calculating clinician performance;
  • A focus on “outcome” measures rather than “process” measures; and
  • Requirements to use 2015 certified EHR technology rather than 2014 certified software.

These negative adjustments, however, also expand the pool of money available to high performers. Now there will be $872 million dollars available to be distributed among providers who meet minimum thresholds as well as those who meet the exceptional performance standards.

Along with the expanded penalties, there will also be new ways for providers to earn potential positive reimbursement adjustments. Among those new options are:

  • Flexible scoring standards for Promoting Interoperability, the newly renamed Advancing Care Information performance category;
  • Incentives for providers’ use of prescription drug monitoring programs;
  • An expanded scope of Improvement Activities, creating additional paths to demonstrate an organizations’ commitment to better care;
  • Facility-based scoring options modeled on the Hospital Value-Based Purchasing (VBP) Program; and
  • Additional scoring and payment incentives to participate in Advanced APMs.

To assess potential risks to your organization’s reimbursement levels and/or to implement a plan to capture positive payment adjustments, please contact  Advis through our website, or by calling 708.478.7030.

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