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CMS Seeks Comments on Physician Payment Reforms

The Centers for Medicare & Medicaid Services (CMS) is soliciting comments on Medicare payment reforms for physicians that will take effect in 2019. CMS requests feedback on a range of provisions relating to the Merit-Based Incentive Payment System (MIPS) and incentives for participation in alternative payment models (APMs). These changes were enacted by legislation that repealed the Medicare sustainable growth rate formula.

Beginning in 2019, MIPS will take the place of separate physician quality programs, namely the Value-Based Payment Modifier, Physician Quality Reporting System, and the Medicare Electronic Health Record (EHR) Incentive Program. Instead of the payment adjustments under these programs, MIPS will offer providers positive or negative payment adjustments depending on a composite score of their performance across four categories. CMS seeks comments on the measures that should be included in these performance categories:

  • Quality
  • Resource Use
  • Clinical Practice Improvement Activities
  • Meaningful Use of Certified EHR Technology (CEHRT)

For the quality performance category, CMS is requesting feedback on whether to require data stratified by race, ethnicity, and gender. Of particular note to hospitals is CMS’ discussion on the use of hospital inpatient quality measures in MIPS. CMS is asking for input on which types of hospital measures to include and how to attribute performance on these measures to physicians. CMS is also asking for comments on whether to continue the current all-or-nothing approach for meaningful use measures in MIPS or whether to use a tiered methodology based on a physician’s performance relative to various percentage thresholds.

Providers who participate in APMs, such as accountable care organizations in the Medicare Shared Savings Program, can be exempt from MIPS and eligible to receive a 5 percent payment bonus. CMS seeks comment on others types of APMs that should be included in determining which providers qualify for this bonus. For example, providers participating in a Medicaid medical home or other APMs under state Medicaid programs may be eligible for the bonus payment.

The request for information will be published in the Federal Register Oct. 1, and comments are due to CMS by Monday, Nov. 2. If you have questions or concerns, please contact Erin O’Malley, director of policy, at or 202.585.0127.


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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