CMS Seeks Comment on Merit-Based Doctor Payment System

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By Mindy Yochelson

Sept. 28 — Physicians and other interested parties have 30 days to weigh in on details for the design of the new Medicare payment system that will replace the sustainable growth rate formula, the Centers for Medicare & Medicaid Services said Sept. 28.

In a request for information (RFI), scheduled to be published Oct. 1 in the Federal Register, the Medicare agency asked the public to comment on the Merit-based Incentive Payment System (MIPS) and participation in Alternative Payment Models (APMs).

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), signed by President Barack Obama in April, established a new reimbursement methodology, which is subject to rulemaking. The law ties annual Medicare reimbursements for doctors and other Part B professionals to value through MIPS, under which payments will be adjusted based on performance measures.

Following a period of statutorily defined payment increases, MIPS in 2019 will replace the current group of incentive payment programs including the Physician Quality Reporting System (PQRS), Value-Based Payment Modifier and the Medicare Electronic Health Record Incentive Program.

Merit-Based Payment

MACRA also encourages the growth of alternative payment models by allowing eligible professionals to avoid possible MIPS-based payment cuts through their participation in such a model.

Specifically, eligible professionals who receive a significant share of their revenues through an eligible APM—most typically a medical home or an accountable care organization—will receive a 5 percent bonus each year from 2019-2024 and be exempt from MIPS.

In its proposed 2016 physician fee schedule rule, the CMS said the RFI would offer details on the framework for the new system.

In the request for comments, the CMS queried the public about a dozen areas pertaining to MIPS.

• MIPS EP Identifier and Exclusions discusses the use of identifiers, such as Tax Identification Numbers, to associate eligible professionals under different programs.

• Virtual Groups establishes a process for letting an individual or a group practice elect to be part of a virtual group with other such professionals or group practices.

• Quality Performance Category deals with the list of quality measures from which professionals may choose for assessment during a performance period.

• Resource Use Performance Category discusses measurement of resource use based on a composite of cost measures.

• Clinical Practice Improvement Activities Performance Category seeks comment on the measures and activities that should be evaluated for practices, including emergency preparedness.

• Meaningful Use of Certified EHR Technology Performance Category looks for input on assessing performance as part of the requirement that 25 percent of a professional's MIPS composite performance score must be determined based on meaningful use of certified technology.

• Other Measures allows the CMS to use measures that are used for other payment systems, such as inpatient hospitals, for performance categories.

• Development of Performance Standards requires the CMS to consider the use of professionals' historical performance standards in order to demonstrate improvement.

• MIPS Composite Performance Score and Performance Threshold requires the CMS to develop a methodology for assessing the total performance of each professional, using a scoring scale of 0 to 100.

• Flexibility in Weighting Performance Categories allows the CMS to assign different scoring weights from those that apply generally under MIPS.

• Public Reporting seeks comments on reporting MIPS measures and activities on Medicare's Physician Compare website.

• Feedback Reports looks for input on the types of information to be provided in confidential feedback.


Alternative Payment Models 

For alternative payment models, the RFI had two large categories.

Under “Information Regarding APMs,” the CMS sets to establish what sort of entity would qualify as an APM.

In the other category, “Information Regarding Physician-Focused Payment Models,” the agency seeks comment on the independent “Physician-focused Payment Model Technical Advisory Committee” that must review comments and make recommendations to the CMS. The RFI asked for input on criteria that the committee could use for assessing recommendations.

To contact the reporter on this story: Mindy Yochelson in Washington at

To contact the editor responsible for this story: Janey Cohen at


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