On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released its final rule implementing the new Quality Payment Program for physicians in lieu of the repealed sustainable growth rate factor (SGR). Rather than facing substantial annual reductions in Medicare payment fees as a result of the SGR, physicians now have two interrelated pathways to earn quality-based, cost efficient incentive payments under Medicare:  the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs). MIPS consolidates three existing quality-based incentives programs – the Physician Quality Reporting System (PQRS), the Physician Value-based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program – while maintaining an ongoing focus on achieving quality and cost efficiencies through use of certified EHR technology (CEHRT).

CMS indicates that substantial changes have been made in response to stakeholder comments. In particular, CMS has implemented transitional policies throughout the rule, including allowing physicians to “pick their pace of participation” for the first performance period beginning January 1, 2017. CMS notes that eligible clinicians will have three flexible options to submit data to MIPS and a fourth option to join Advanced APMs to promote participation and avoid negative payment adjustments in 2019. CMS also has established a $100 million ($20 million each over a five year period of time) technical assistance program for small independent practices, particularly those in rural and health professional shortage areas.

The details are many. In releasing its final rule, CMS also makes available information regarding the criteria for and operational requirements of each of these programs. Click here to learn more: http://www.hhs.gov/about/news/2016/10/14/hhs-finalizes-streamlined-medicare-payment-system-rewards-clinicians-quality-patient-care.html.

The final rule becomes effective on January 1, 2017. CMS also provides a 60-day opportunity for stakeholder comment on specific issues identified throughout the rule. The final rule has been released in prepublication form at https://qpp.cms.gov/docs/CMS-5517-FC.pdf, with formal publication in the Federal Register slated for a future date.