CMS published its Final Rule update to MIPS and APM in MACRA on 10/14/2016. This information is critical for physicians who are trying to navigate the shift in reimbursement from "volume" to "value." The bottom line is, pay now or pay later.

The following discussion is courtesy of MBX:


On Friday, October 14th, the Centers for Medicare & Medicaid Services (CMS) released the long awaited Final Rule for the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive payment provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Along with this policy came the announcement of
a new Quality Payment Program (the collective term for MIPS and APMs) website which is a valuable resource for eligible clinicians. Quality Payment Program (QPP) website contains detailed information on MIPS, APMs, how to participate, reporting options, MIPS measures and activities, access to the Final Rule, MACRA legislation, and many more helpful links.

Final Rule differed from the proposed rule in a few ways, including having 2017 be a “transition” year in which 4 MIPS participation options are available for eligible clinicians:

  1. Report to MIPS for a full 90-day period (or ideally the full year); exceptional performers are eligible for an additional positive adjustment for each of the first 6 years of the program.

  2.  Report to MIPS at least for a full 90-day period but less than the full year, and report more than one quality measure and improvement activity, or more than the required measures in the advancing care information performance category to avoid a negative MIPS payment adjustment and possibly receive a positive MIPS payment adjustment.

    3. Report one measure in the quality performance category, one activity in the improvement activities performance category, OR report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment. Eligible clinicians opting to NOT report even one measure or activity will receive the full negative 4% payment adjustment.

    4. MIPS eligible clinicians can participate in Advanced APMs, and if they receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM, they will quality for a 5% bonus incentive payment in 2019.

    5. Under the Final Rule, small practices are given protection under the QPP. Low-volume thresholds have been set for exclusion from MIPS: less than or equal to $30,000 in Medicare Part B allowed charges, or less than or equal to 100 Medicare patients.

    6. Another important change from the Proposed Rule to the Final Rule surrounds the “non patient facing” exemption. The proposal was to allocate this exemption by specialty, however, the Final Rule changes it to threshold based. The exemption will now apply to eligible clinicians who have 100 or less patient-facing encounters during the 12-month determination period September 2015 to August 2016. In addition, the Rule states that if 75% of a group’s physicians meet the non-patient facing criteria, then the entire group does as well.  This is good news for interventional radiologists – Danny Hughes, PhD, of the Harvey L. Neiman Health Policy Institute says, “This will allow radiologists that primarily perform interventional procedures to continue to add value to their groups without adversely affecting the group’s opportunities to succeed in performance review under MIPS”.


    The QPP website can be accessed here: