While the proposed rule is incredibly complex — 962 pages — here are some early takeaways. We promise to keep you posted with any future developments.

• There are two paths to reimbursement, beginning CY2017  for Medicare eligible clinicians : the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Models (APMs). Though initially this affects practices who receive a large portion of their reimbursement from Medicare, private payers will probably follow suit
• Providers will have to begin attestation under one of these two models in 2017, and will receive their first payments under the new framework in 2019. Both MIPS and APMs are value-based payment models that incentivize providers on quality, outcomes and cost containment
• The proposed rule, so far, onlyapplies to Medicare and physician practices. Hospitals will be addressed later this year
• Medicaid will notparticipate in the program. This means for physicians, who are eligible for Meaningful Use and other programs under Medicaid, those programs would presumably continue
• MIPS will consolidate three currently disparate Medicare quality programs into one: (1) the Physician Quality Reporting System; (2) the Value-Based Modifier Program; and, (3) the ‘Meaningful Use’ of electronic health records
• CMS proposes that eligible clinicians receive a composite score relative to their performance in each of four categories. Quality measures for these core domains will be selected annually, with the data regarding clinician performance on the measures made available via the Physician Compare website
• Unlike PQRS, where there were nine quality measures, the MIPS “Quality” part will ask physicians to choose six quality measures to report on; from a list of options tailored to specialty and practices. According to CMS, for individual clinicians and small groups (2-9 clinicians), MIPS will calculate two population measures based on claims data, meaning there are no additional reporting requirements for clinicians for population measures
• The proposed rule has the reporting period set at a full year

Meaningful Use Re-branded 

• Meaningful use has been re-branded as Advancing Care Information program. What’s the big difference?
  1. The thresholds for Meaningful Use stage 2 and 3 requirements have been either significantly lowered or eliminated. For example on patient engagement, one instance of “active patient engagement” with the EHR, one secure message exchange and one use of patient-generated health data among the doctor’s entire Medicare patient load during calendar year 2017 (the first performance period), qualifies a clinician for part of the MIPS bonus
  2. Reduction in the number of measures to an all-time low of 11 measures, down from 18 measures. Reporting on clinical decision support and computerized provider order entry measures will not be required
  3. The new program makes physicians’ reporting participation “customizable”. Physicians or clinicians can choose which measures best fit their practice.

MIPS & APMs

• All physicians — with a few exceptions—will report through MIPS in the first year of the program. That data will then be used by CMS to determine which providers met the requirements for the APM track. There are requirements on how many payments through an APM you receive to be eligible, and for the first few years, it can only be Medicare patients and payers. In subsequent years, CMS says it will allow physicians in these models to include non-Medicare payers and patients and the number will increase. Physicians are not locked into their choice — they can switch between MIPS and APM annually
• According to the Healthcare Financial Management Association, the recent MACRA rule identified specific eligible APMs that will qualify for bonus payments and exemption from MIPS reporting. These include:
  • Next Generation ACO
  • Comprehensive Primary Care Plus (CPC+)
  • Medicare Shared Savings Program (MSSP) Tracks 2 and 3
  • Oncology Care Model with two-sided risk
  • Comprehensive ESRD Care (for large dialysis organizations)

Currently, ninety-five percent of MSSP ACOs are participating in Track 1 of the program, which would not qualify them for an exemption from MIPS. These providers, who do not currently accept downside risk from Medicare, would have to attest to the MIPS program instead

P.S: Many of the APM deadlines are fast approaching. Applications for the Shared Savings Program, for instance, are due as soon as May 31.

• Clinicians can be exempt from MIPS if they are new to Medicare, have less than $10,000 in Medicare charges or see 100 or fewer Medicare patients or are “significantly participating” in an advanced APM
• MIPS clinicians can report as an individual, group or through third-party data submission entities, specifically: qualified registries, QCDRs, health IT vendors, and CMS-approved survey vendors, who would have the ability to act as intermediaries on behalf of MIPS eligible clinicians and groups, for submission of data to CMS across the quality, CPIA, and advancing care information performance categories

To learn how to prepare your practice for quality programs watch CureMD webinar The Bumpy Road Ahead : Challenges facing physician practices in 2016.