Richard J. Zall, Edward S. Kornreich and Mara Wilber of Proskauer Rose LLP wrote an article in Law 360 discussing the trends in physician pay after the Medicare Access and CHIP Reauthoraization Act was signed into law and began implementation earlier this year.
Here are eight things to know about Medicare reimbursement going forward:
1. Physicians will receive a zero to 100 performance score based on four weighted performance standards: Quality, advancing care information, clinical practice improvement activities and resource use. The first performance period occurs in 2017.
2. The data reported in 2017 through the Merit-Based Incentive Payment System next year will impact the payments in 2019.
3. Next year is the first year of the Qualified Professionals participating in Advanced Payment Models. The data reported in 2017 will determine which clinicians meet requirements for becoming qualified professionals in APMs.
4. The MIPS aggregated payment increases over time. MIPS is budget-neutral, so Medicare will use scores to compute positive, negative or neutral adjustments. In 2019, the adjustments are 4 percent; in 2020 they are 5 percent. By 2022 and after, adjustments are 9 percent.
5. There will be greater public reporting and transparency; beginning July 1, 2017, CMS is proposing to provide performance feedback to physicians on MIPS quality and resource use. CMS also continues publishing data through Physician Compare.
6. CMS will include all-payer combination options starting in 2021, allowing physicians to qualify for incentive payments. The qualifications are based in part on participation in Advanced APMs. An Advanced APM must use certified EHR technology and provide payment based on quality measures comparable to MIPS's quality performance category, in addition to other requirements.
7. The system is designed for clinicians to easily move between the MIPS track and Advanced APM track.
8. CMS figures there will be around 687,000 to 746,000 eligible clinicians in MIPS to distribute payment adjustments. The agency seeks to provide budget neutrality with $833 million in distributed negative and $833 million positive payment adjustments. There could be around $500 million distributed in exceptional performance payments.
"The cost burden of compliance, in the context of overall Medicare payment increases over the next four years that will be substantially less than the rate of inflation, may make it increasingly difficult for smaller practices to survive, and may increase the number doctors who opt out of Medicare in some high end urban markets," wrote the article's authors.