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Physician Payment Reform

The passage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Sustainable Growth Rate (SGR) and replaced it with two new payment update tracks, the Merit-based Incentive Payment System (MIPS) and CMS Alternative Payment Models (APMs). Payment adjustments under the MIPS and APM programs are scheduled to go into effect January 1, 2019.

MACRA created the MIPS to replace
the current CMS Quality Initiative
Programs. MIPS incorporates aspects
of several CMS quality programs into
a component score to determine physician payment.

Learn More about MIPS

APMs are a new approach to paying for medical care
incorporating quality and total cost of care,
instead of a traditional fee-for-service payment structure.

Learn More about APMs

What You Need to Know about MIPS Year 3

CMS implemented extensive udates for the third year of the Merit-based Incentive Payment System (MIPS). Key programmatic changes for 2019 address eligible clinicians, technology requirements, performance categorires, scoring methodology, measures and objectives, as well as thresholds and bonus points. The items below highlight some of the major changes for Year 3 (Y3) that AAO-HNS members need to know:

  1. More MIPS eligigble clinicians - Eligible Clinicians (ECs) represent the same five provider groups from Y2, but now also include additional practitioners such as qualified audiologists, clinical physical therapists, occupational therapists, qualified speech-language pathologists, and reigstered dieticians or nutrition professionals. 
  2. 2015 Certified Electronic Health Records Technology (CEHRT) required - Submission of data in each of the following performance categories now requires 2015 CEHRT: Quality, Improvement Activities, and Promoting Interoperability. 
  3.  Modified performance category weights - The weighting of the QUality category decreased from 50 percent to 45 percent of the final MIPS score. while the Cost category increased to 15 percent. Promoting Interoperability and Improvement Activities categories remain the same (25 percent and 15 percent, respectively). 
  4. Restructured Promoting Interoperability performance category - This performance category includes the following new element

    -Base, performance, and bonus scores were eliminated and replaced with a new scoring methodology (100 total category points)
    -Two new e-perscribing objectives are available; and
    -ECs must meet four objectives: e-perscribing, health information exchange, provider to patient exchange, and public health and clinical data exchange, unless an exclusion is granted. ECs are also required to report certain measures associated with the objectives.
  5. New Quality measures - CMS added eight new quality measures for 2019 and removed 26 measures that were duplicative or "topped out."
  6. Increased thresholds to avoid penalties and obtain bonus points - ECs and groups must earn at least 30 points (an increase from the 15 points required in 2018) to ensure a neutral payment adjustment. ECs and groups seeking a performance bonus must also earn at least 75 MIPs points (an increase from 70 points n 2018).
  7. Modified small practice point system - Small practices (<15) will still receive a small practice bonus, but for 2019, the bonus is now reflected in the Quality performance category score instead of a standalone bonus. If ECs submit data on at least one Quality measure, the bonus points will be increased to six points (as compared to five points in 2018).
  8. MIPS Opt-In policy - ECs or groups may opt-in to MIPs if they exceed at least one, but not all three, of the low-volume threshold criteria.

AAO-HNS Brochure for Year Two of the Quality Payment Program is Now Available - 2/21/2018

  • To assist members with participation in Year Two of the Quality Payment Program (QPP), the Academy developed an updated brochure outlining programmatic changes for 2018.
  • The brochure primarily highlights changes to MIPS, as most AAO-HNS members will participate in the QPP via this pathway.

To access the new brochure, click here.

Academy Fact Sheet for Year 2 of the Quality Payment Program is Now Available - 1/11/2018

  • To assist members with participation in Year 2 of the Quality Payment Program (QPP), the Academy developed a fact sheet to highlight the program’s changes, as established in the CY 2018 QPP final rule.
  • The fact sheet highlights changes to MIPS, performance categories, participation requirements, and APMs, among other provisions.

To access the Fact Sheet, click here.

CMS Releases Final Quality Payment Program for CY 2018 - 11/9/2017

• The Centers for Medicare and Medicaid Services (CMS) issued the final rule for Year 2 of the QPP, addressing 2018 requirements and future years under the Merit-Based Incentive Payment System and the Advanced Alternative Payment Model programs. 

• An interim final rule was also released for extreme and uncontrollable circumstances where clinicians can be automatically exempt from these categories without submitting a hardship exception application, if they were affected by extreme weather conditions that occurred during the 2017 MIPS performance period.

  • Access the final rule here
  • Read the CMS Year 2 Fact Sheet here
  • Review the Executive Summary here

• CMS listened and worked to address many of the concerns raised by the AAO-HNS in our comment letter on the proposed rule. However, we emphasized the importance of the need to continue to work together with CMS to address remaining concerns about the program, including continued complexity of the programs and the additional burdens placed on members who must understand and meet many of the shifting requirements. 

  • To read the letter submitted to CMS for the QPP final rule, please click here
  • To read the letter submitted to CMS for the QPP proposed rule, please click here

• For questions regarding 2018 final requirements, contact the Health Policy team at healthpolicy@entnet.org

CMS Releases Quality Payment Program (QPP) Resources

• CMS added additional resources to the QPP website to help clinicians participate in the MIPS and APM programs. Resources include a MIPS Quick Start Guide and updated fact sheets. Clinicians can also access a web tool on the QPP webpage to check their MIPS participation status. Clinicians can access these resources on the QPP webpage here

APMs are a new approach to paying for medical care incorporating quality and total cost of care, instead of a traditional fee-for-service payment structure.