Merit-based Incentive Payment System (MIPS)

Merit-based Incentive Payment System (MIPS) / en Sat, 26 Apr 2025 18:47:46 -0500 Mon, 12 Aug 24 17:57:51 -0500 CY 2025 Physician Fee Schedule Proposed Rule Webinar In this webinar, AHA staff discussed the recently&nbsp;released <a href="https://chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://public-inspection.federalregister.gov/2024-14828.pdf">CY 2025 Physician Fee Schedule proposed rule.</a> This rule proposes updates to physician fee schedule&nbsp;rates, changes to telehealth services, updates for behavioral health and opioid use disorder, and other&nbsp;aspects of physician payment. The rule also proposes changes to the Medicare Shared Savings Program (MSSP)&nbsp;and Quality Payment Program (QPP) created by the Medicare Access and CHIP Reauthorization Act (MACRA) of&nbsp;2015.&nbsp; &nbsp;See the <a href="/2024-07-31-medicare-physician-fee-schedule-proposed-rule-cy-2025">AHA Regulatory Advisory</a> for a summary of the rule. Members can <a href="https://aha-org.zoom.us/rec/share/Ozc6eCdUVw5YQz3c3Mnwjt9iQWektk9lsKKRQJMQHdjjoxJ1f_EKjKU-T_TW1JKw.yyusAHVAqgI0hus4?startTime=1723222710000">view the recording of the session </a>and download slides below for further review. Mon, 12 Aug 2024 17:57:51 -0500 Merit-based Incentive Payment System (MIPS) HHS releases final rule disincentivizing health care providers that commit information blocking /news/headline/2024-06-24-hhs-releases-final-rule-disincentivizing-health-care-providers-commit-information-blocking The Department of Health and Human Services June 24 released a <a href="https://www.hhs.gov/about/news/2024/06/24/hhs-finalizes-rule-establishing-disincentives-health-care-providers-that-have-committed-information-blocking.html">final rule</a> that would disincentivize health care providers for interfering with the access, exchange or use of electronic health information. AHA previously expressed <a href="/lettercomment/2024-01-02-aha-comments-21st-century-cures-act-establishment-disincentives-health-care-providers-have-committed">concern</a> when the rule was proposed, saying it could threaten the financial viability of economically fragile hospitals. In the final rule, hospitals under the Medicare Promoting Interoperability Program found to have committed information blocking would experience a reduction of the market basket update by 75%. Critical access hospitals would see a reduction from 101% to 100% of reasonable costs, while clinicians in Medicare's Merit-based Incentive Payment System would receive a score of zero in the MIPS Promoting Interoperability performance category. Providers in accountable care organizations that commit information blocking would be ineligible to participate in the Medicare Shared Savings program for at least one year and may not receive revenue they may have earned through the program.&nbsp; AHA is disappointed that HHS chose to disregard most of the comments they received and is highly concerned that the disincentive structure retained in the final rule is excessive, confusing and imbalanced. Mon, 24 Jun 2024 14:42:51 -0500 Merit-based Incentive Payment System (MIPS) Medicare Physician Fee Schedule Proposed Rule for CY 2024 <div class="container"> <div class="row"> <div class="col-md-8"> The Centers for Medicare &amp; Medicaid Services (CMS) July 13 issued its physician fee schedule <a href="https://public-inspection.federalregister.gov/2023-14624.pdf" target="_blank">proposed rule</a> for calendar year (CY) 2024. The rule also includes proposals related to the Medicare Shared Savings Program (MSSP) and the Quality Payment Program (QPP), both of which were created by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. Comments on the proposed rule are due to CMS by Sept. 11. The final rule will be published on or around Nov. 1, and policies would generally take effect Jan. 1, 2024. <div class="panel module-typeC"> <div class="panel-heading"> <h3>Key Highlights</h3> CMS’ proposed policies would: <ul> <li>Reduce the PFS conversion factor by 3.34% to $32.75, as compared to $33.89 in CY 2023</li> <li>Delay for at least one year implementation of a policy that would define the substantive portion of a split (or shared) visit based on the amount of time spent by the billing practitioner</li> <li>Delay implementation of the rebased and revised Medicare Economic Index (MEI) until future rulemaking</li> <li>Extend several telehealth waivers through 2024, which were outlined in the Consolidated Appropriations Act (CAA) of 2023; as well as regulatory waivers for virtual supervision and billing for virtual therapy services</li> <li>Revise the data reporting period and phase-in of payment reductions for clinical laboratory tests under the Clinical Laboratory Fee Schedule (CLFS)</li> <li>Pause the Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging program indefinitely in order to conduct further evaluation</li> <li>Permit the reporting of Medicare-only clinical quality measures in the MSSP</li> <li>Add five new Merit-Based Incentive Payment System (MIPS) Value Pathways for CY 2023</li> <li>Increase the MIPS performance threshold for achieving positive payment adjustments</li> <li>Offer Advanced Alternative Payment Model (APM) track bonus payments in 2025 to those that qualify</li> </ul> </div> </div> <h2>AHA TAKE</h2> The AHA is concerned with CMS’ proposed payment update, which would substantially reduce CY 2024 payments from their CY 2023 levels. This update would pose significant risks to patients’ access to care and health systems’ financial stability, particularly for safety-net providers. Our concern is heightened by the fact that this cut is coming in the wake of over three years of unrelenting financial pressures on the health care system due to COVID-19, along with rising inflation, increasing input costs, and persisting staffing shortages and supply chain disruptions. However, we are pleased that CMS is proposing to delay implementation of its split/shared visit policy and revised MEI, which would have resulted in significant reductions and redistributions in physician revenue on top of this proposed rule’s other cuts. We are also encouraged by the proposed reevaluation of the Appropriate Use Criteria for Advanced Diagnostic Imaging program. We have expressed longstanding concerns that the current program could result in inappropriate claims denials, increased administrative burden and ultimately unnecessary delays in patient care. Finally, we thank CMS for proposing to extend through 2024 many of the COVID-19 telehealth flexibilities. In addition, the AHA continues to encourage CMS to work with Congress on permanent adoption of waiver provisions such as eliminating the originating and geographic site restrictions for all telehealth services and expanding telehealth eligibility to certain practitioners. We also encourage CMS to leverage statutory authority to make permanent certain waivers through regulation. <h2>WHAT YOU CAN DO</h2> <ul> <li>Share this advisory with your chief medical officer, chief financial officer and other members of your senior management team, as well as key physician leaders and nurse managers.</li> <li>Register <a href="https://aha.adobeconnect.com/eqh0x35e8ws5/event/registration.html" target="_blank">here</a> to participate in AHA’s member-only webinar on Wednesday, Aug. 23 at 4 p.m. ET to discuss the proposed rule.</li> <li>Assess the potential impact of the proposed payment and quality changes on your Medicare revenue and operations.</li> <li>Submit comments to CMS with your specific concerns by Sept. 11 at <a href="http://www.regulations.gov/" target="_blank">www.regulations.gov</a>.</li> </ul> <h3>View the detailed Regulatory Advisory below.</h3> </div> <div class="col-md-4"> <a href="/system/files/media/file/2023/08/medicare-physician-fee-schedule-proposed-rule-for-cy-2024-advisory-8-2-23.pdf" target="_blank"><img alt="Cover Medicare Physician Fee Schedule Proposed Rule for CY 2024 Advisory" data-entity-type="file" data-entity-uuid="78ba80f3-efb8-4331-9219-87dad779124a" src="/sites/default/files/inline-images/cover-medicare-physician-fee-schedule-proposed-rule-for-cy-2024-advisory-8-2-23.png" width="510" height="659"></a> </div> </div> </div> Wed, 02 Aug 2023 14:46:15 -0500 Merit-based Incentive Payment System (MIPS) March 31 deadline for Promoting Interoperability, GME and MIPS approaching /news/headline/2022-03-25-march-31-deadline-promoting-interoperability-gme-and-mips-approaching Medicare eligible hospitals and critical access hospitals must <a href="https://hqr.cms.gov/hqrng/login">attest</a> to meaningful use of electronic health records for the 2021 Promoting Interoperability Program reporting period by March 31 at 11:59 p.m. ET. For more on 2021 program requirements, visit the <a href="https://www.cms.gov/regulations-guidance/promoting-interoperability/2021-program-requirements">CMS website</a>. &nbsp;&nbsp; &nbsp; &nbsp; March 31 is also the <a href="https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2022-03-24-mlnc#_Toc98856008">deadline to apply</a> for additional residency positions for fiscal year 2023 under Section 126 of the Consolidated Appropriations Act of 2021, which will phase in 1,000 new Medicare-funded residency positions beginning with up to 200 in FY 2023. &nbsp; &nbsp; &nbsp; &nbsp; In addition, Merit-based Incentive Payment System eligible clinicians who participated in the Quality Payment Program’s <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1797/2021%20Data%20Submission%20User%20Guide.pdf">2021 performance year</a> may submit data until 8 p.m. ET on March 31. Fri, 25 Mar 2022 14:28:45 -0500 Merit-based Incentive Payment System (MIPS) CMS announces automatic exception policy for MIPS individual clinicians /news/headline/2021-11-10-cms-announces-automatic-exception-policy-mips-individual-clinicians Due to the COVID-19 public health emergency, the Centers for Medicare &amp; Medicaid Services will apply an automatic extreme and uncontrollable circumstances policy to all clinicians participating as individuals in the Quality Payment Program’s Merit-based Incentive Payment System for the 2021 performance period, the agency <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1437/2021%20MIPS%20Automatic%20EUC%20Fact%20Sheet.pdf">announced</a> today. The automatic policy does not apply to groups, virtual groups or alternative payment model entities, who may apply through Dec. 31 at 8 p.m. ET for an extreme and uncontrollable circumstances exception. Wed, 10 Nov 2021 09:52:55 -0600 Merit-based Incentive Payment System (MIPS) CMS reweighting MIPS 2020 cost performance category /news/headline/2021-05-20-cms-reweighting-mips-2020-cost-performance-category The Centers for Medicare &amp; Medicaid Services will reweight the cost performance category for the Merit-based Incentive Payment System from 15% to 0% for the 2020 performance period — which affects 2022 payments — due to the impact of the COVID-19 public health emergency, and redistribute the 15% prescribed weight to another performance category or categories.&nbsp; “Our analysis of the underlying data for the 2020 performance year, in comparison to prior years’ data, shows that the volume of data available to calculate the scores for the cost measures has significantly decreased overall,” CMS said. “As a result, we do not believe we can reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians.” Because the cost performance category relies on administrative claims data, clinicians do not need to take any action, CMS said. For more on the Quality Payment Program, visit the <a href="https://qpp.cms.gov/">QPP website</a>.&nbsp; &nbsp; Thu, 20 May 2021 14:57:28 -0500 Merit-based Incentive Payment System (MIPS) CMS announces automatic exception policy for MIPS individual clinicians /news/headline/2021-02-26-cms-announces-automatic-exception-policy-mips-individual-clinicians Due to the COVID-19 public health emergency, the Centers for Medicare &amp; Medicaid Services will apply an automatic extreme and uncontrollable circumstances policy to all clinicians participating as individuals in the Quality Payment Program’s Merit-based Incentive Payment System for the 2020 performance period, the agency <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/966/QPP%20COVID-19%20Response%20Fact%20Sheet.pdf">announced yesterday</a>. Under the policy, MIPS will score individual clinicians only on the performance categories for which they submitted data. Those who have not submitted 2020 data or submitted data for only one performance category will automatically receive a neutral payment adjustment for 2022. The automatic policy does not apply to groups, virtual groups or alternative payment model entities, who may apply through March 31 at 8 p.m. ET for an extreme and uncontrollable circumstances exception. Fri, 26 Feb 2021 15:00:35 -0600 Merit-based Incentive Payment System (MIPS) CMS extends deadline for clinicians to apply for COVID-19 MIPS exception /news/headline/2020-12-18-cms-extends-deadline-clinicians-apply-covid-19-mips-exception The Centers for Medicare &amp; Medicaid Services <a href="https://qpp.cms.gov/mips/exception-applications#extremeCircumstancesException-2020">has extended</a> to Feb. 1 at 8 p.m. ET the deadline for clinicians participating in the Merit-based Incentive Payment System to <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1054/2020%20MIPS%20Exception%20Applications%20Fact%20Sheet.pdf">apply</a> for an extreme and uncontrollable circumstances exception&nbsp;to reweight the MIPS performance categories. “If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application,” the agency said. CMS <a href="https://qualitynet.cms.gov/news/5fda9de4e606810025a62941">yesterday extended</a> the third quarter 2020 data submission deadlines for several quality reporting and value programs for hospitals, post-acute care and other providers during the public health emergency. Fri, 18 Dec 2020 14:36:26 -0600 Merit-based Incentive Payment System (MIPS) CMS releases Quality Payment Program results for 2019 /news/headline/2020-10-28-cms-releases-quality-payment-program-results-2019 Ninety-eight percent of eligible clinicians who reported data in the 2019 Quality Payment Program through the Merit-based Incentive Payment System track will receive a positive payment adjustment in 2021, with 84% receiving an additional adjustment for exceptional performance, the Centers for Medicare &amp; Medicaid Services <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1190/QPP%202019%20Participation%20Results%20Infographic.pdf">announced</a> yesterday. Despite the challenges caused by the COVID-19 public health emergency, 97% of MIPS-eligible clinicians submitted some data at the individual, group, virtual group or alternative payment model level, including 85% of eligible clinicians in small practices, CMS said. Another 195,564 clinicians participated in the QPP through the advanced alternative payment model track to qualify for a 5% bonus payment in 2021, up from 183,306 in 2018. Wed, 28 Oct 2020 15:06:30 -0500 Merit-based Incentive Payment System (MIPS) Deadline to request MIPS targeted review approaching /news/headline/2020-09-29-deadline-request-mips-targeted-review-approaching Clinicians who participated in the Merit-based Incentive Payment System in 2019 have until Oct. 5 at 8 p.m. ET to review their final score and payment adjustment factor(s) for 2021 and <a href="https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1109/2019%20Targeted%20Review%20User%20Guide.pdf">request a targeted review</a> if they suspect an error. The final score determines the payment adjustment applied to the Medicare paid amount for covered professional services furnished by a MIPS eligible clinician in 2021. Tue, 29 Sep 2020 14:35:21 -0500 Merit-based Incentive Payment System (MIPS)