Quality Payment Program
The Quality Payment Program, including the Merit-based Incentive Program System (MIPS) and Advanced Payment Models (APMs), has united Medicare Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Value-based Modifier (VBM) into one program. The Centers for Medicaid and Medicare has implemented MIPS to reduce the burden on eligible clinicians participating in multiple programs to escape Medicare penalties and earn incentives.
Merit-based Incentive Program System (MIPS)
2017 is the performance year for clinicians to gather quality data for the Quality Payment Program. The Performance Year opened January 1, 2017 and will close December 31, 2017. Clinicians will need to send data to CMS before the March 31, 2018 deadline to potentially earn a positive or negative payment adjustment. Medicare will give feedback based on submitted data. Payment adjustments, positive or negative will begin January 1, 2019.
Types of Eligible Clinicians
Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists.
Eligible clinicians must bill more than $30,000 per year in Medicare Part B AND administer care for more than 100 Medicare patients.
In order to participate all clinicians must achieve both the above requirements to be considered eligible.
Types of Ineligible Clinicians
- Clinicians newly enrolled in Medicare are exempt until the following performance year.
- Clinicians with Medicare Part B allowable charges that are equal to or below $30,000 in a calendar year OR see 100 Medicare patients or less in a calendar year.
- Clinicians who participate in an Advanced Alternative Payment Model (APM) for more information about qualified APMs please follow this link to CMS.
Clinicians can pick a pace for performance year 2017 by choosing to participate in an Advanced Alternative Payment Model (APM) or have a choice to submit under MIPS for a partial year or for a full year or to test. If submitting for a 90-day period in 2017 you can start anytime between January 1, 2017 to October 2, 2017.
Image courtesy of CMS
Alternative Payment Models (APMs)
Alternative Payment Models (APMs) are different tracks of paying for medical care through Medicare. APMs can apply to a specific clinical conditions, care episodes, or a population.
If participating in an APM, you will receive MIPS adjustments both negative or positive and APM specific rewards. Therefore, clinicians can receive incentives for quality and cost efficient care with less risk of participating in an Advanced APMs.
Advanced Alternative Payment Models (Advanced APM)
Advanced APMs are a subsection of APMs. Participating in an Advanced APM can earn eligible clinician’s specific rewards plus a 5% lump sum incentive due to taking some risk associated to their patient’s outcomes. If you qualify to participate in an Advanced APM you would be excluded from MIPS. Qualifying APM Participants (QP) are clinicians who have a certain percentage of Medicare Part B payments for professional services or patients furnished Part B professional services through an Advanced APM Entity.
Criteria to participate in an Advanced APM
Clinicians must use certified EHR technology, provide payment for covered professional services based on quality measures comparable to those used in the MIPS quality performance category;
and either is a Medical Home Model expanded under CMS Innovation Center authority OR
participants are required to bear a more than nominal amount of financial risk.
2017 CMS Models of Advanced APMs
- Comprehensive End Stage Renal Disease Care Model (Two-Sided Risk Arrangements)
- Comprehensive Primary Care Plus (CPC+)
- Shared Savings Program Track 2
- Shared Savings Program Track 3
- Next Generation ACO Model
- Oncology Care Model (Two-Sided Risk Arrangement)
Please follow this link to find a list of Advanced APMs.
CMS anticipates future performance years’ models of Advanced APMs
- Comprehensive Care for Joint Replacement (CJR) Payment Model (CEHRT)
- New Voluntary Bundled Payment Model
- Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT)
- Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model)
- ACO Track 1+
- CMS MIPS Overview
- CMS MIPS Checklist
- MIPS Summary - Performance Categories, Submission Methods & Groups
- Payment Adjustments & Hardship Exceptions
- CDPHE Meaningful Use Registration Page
- EH Attestation Worksheet for Modified Stage 2 Medicare
- Objectives and Measures Table for EHs (CMS document)
- Final Rule (November 2016)
- Recorded Webinars and Videos from CMS
Questions on the EHR Incentive Programs?
Medicaid - Contact the Medicaid EHR Incentive Program Coordinator at medicaidEHR@corhio.org or 720-285-3232.